Anti-Money Laundering (AML)
Firms must comply with the Bank Secrecy Act and its implementing regulations ("AML rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation.
FINRA reviews a firm’s compliance with AML rules under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program. The basic tenets of an AML compliance program under FINRA 3310 include the following.
- The program has to be approved in writing by a senior manager.
- It must be reasonably designed to ensure the firm detects and reports suspicious activity.
- It must be reasonably designed to achieve compliance with the AML Rules, including, among others, having a risk-based customer identification program (CIP) that enables the firm to form a reasonable belief that it knows the true identity of its customers.
- It must be independently tested to ensure proper implementation of the program.
- Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).
- Ongoing training must be provided to appropriate personnel.
- The program must include appropriate risk-based procedures for conducting ongoing customer due diligence, including (i) understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and, (ii) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, including information regarding the beneficial owners of legal entity customers.
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Anti-Money Laundering Template for Small Firms
FINRA provides an Anti-Money Laundering Template to assist Small Firms in establishing the AML compliance program required by the Bank Secrecy Act, its implementing regulations, and FINRA Rule 3310.
Frequently Asked Questions
Find answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.
AML Reports and Systems
- Suspicious Activity Report (SAR) (must be filed electronically through the BSA E-Filing System)
- Currency Transaction Report (CTR) (must be filed electronically through the BSA E-Filing System)
- Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN 114) (must be filed electronically through the BSA E-Filing System)
- Report of International Transportation of Currency or Monetary Instruments (CMIR)
- Section 314(a) Secure Information Sharing System
- OFAC Reporting System for Blocked and Rejected Transactions
FINRA's Anti-Money Laundering (AML) e-learning courses cover concepts and strategies for detecting and preventing money-laundering activity. Each course presents unique scenarios that illustrate typical money-laundering situations.
FINRA's Office of General Counsel (OGC) staff provides broker-dealers, attorneys, registered representatives, investors and other interested parties with interpretative guidance relating to FINRA’s rules. Please see Interpreting FINRA Rules for more information.
OGC staff contacts:
- FINRA Urges Firms to Review Their Policies and Procedures Relating to Red Flags of Potential Securities Fraud Involving Low-Priced Securities02/10/2021
- FINRA Reminds Firms to Beware of Fraud During the Coronavirus (COVID-19) Pandemic05/05/2020
- FINRA Provides Guidance to Firms Regarding Suspicious Activity Monitoring and Reporting Obligations05/06/2019
- FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions10/19/2018
- FINRA Amends Rule 3310 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions05/03/2018
- FINRA Provides Guidance to Firms Regarding Anti-Money Laundering Program Requirements Under FINRA Rule 3310 Following Adoption of FinCEN's Final Rule to Enhance Customer Due Diligence Requirements for Financial Institutions Effective Date: *11/21/2017
- SEC Requests Broker-Dealers Make SARs and SAR Information Available to FINRA02/10/2012
- SEC Approval and Effective Dates for New Consolidated FINRA Rules10/15/2009
- NASD and NYSE Joint Release Regarding Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act04/18/2007
- Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act08/14/2006
- SEC Approves Amendments to Anti-Money Laundering Compliance Program Rule and Adoption of Interpretive Material02/10/2006
- Treasury and SEC Issue Final Rule Regarding Customer Identification Programs for Broker/Dealers06/20/2003
- Development Regarding Treasury Information Requests Under Section 314 of the PATRIOT Act12/02/2002
- NASD Adopts Amendments to Rule 3011 to Require Members to Provide to NASD Contact Information for an Anti-Money Laundering Compliance Person(s)10/31/2002
- Treasury and SEC Request Comment on Proposed Regulation Regarding Broker/Dealer Anti-Money Laundering Customer Identification Requirements08/13/2002
- Treasury Issues Final Suspicious Activity Reporting Rule for Broker/Dealers08/12/2002
- NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law04/10/2002
- Executive Order Targeting Terrorists10/10/2001
- FAQAnswers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.
- GuidanceThe Anti-Money Laundering, Fraud and Sanctions topic of the 2024 FINRA Annual Regulatory Oversight Report (the Report) informs member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations, including (1) regulatory obligations and related considerations, (2) findings and effective practices, and (3) additional resources.January 09, 2024
- Media CenterMoney laundering looks different in the securities industry and that poses its own challenges. Add to that a landscape of constantly evolving threats and it is a lot to keep up with. On this episode, we hear about emerging threats and how firms can ensure their AML program remains strong and effective.May 31, 2022
The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection (NCFC) program is bringing to your attention some additional Russia-related sanctions developments. Please note that these are in addition to those detailed in FINRA Regulatory Notice 22-06.February 28, 2022
- PodcastA broker-deal firm’s anti-money laundering efforts may overlap with any number of other regulatory concerns. On this episode, the second in a two-part series, we’re looking at how AML may overlap with a firm’s efforts to protect senior investors from exploitation and fraud.November 10, 2020
- PodcastFirm regulatory risks and priorities don't exist in a vacuum. And that is perhaps nowhere clearer than when it comes to a firm's anti-money laundering responsibilities. A firm's AML risks can overlap with any number of other priorities. On this episode, the first of a two-part series, we look at the overlapping risks of AML and cybersecurity.October 27, 2020
- PodcastThis episode originally aired in April 2019. The only thing many people know about money laundering is what they’ve learned from Hollywood. So if you want to really understand what money laundering is, and more specifically, the efforts brokerage firms must take to prevent and detect it, tune in. On this episode we talk to two of FINRA’s Anti-Money Laundering experts.August 04, 2020
- Virtual Conference PanelCOVID-19 has altered the world as we know it. While some have responded to it as an incident or singular event, in the world of countering criminal threats we are seeing the need to treat it as a sustained campaign. This panel will discuss the multitude of threats across the financial crimes’ spectrum perpetrated by an aggressive yet flexible adversary.June 09, 2020
- PodcastBetween the level of interconnectedness on the web and the sheer about of data available, we’re living in an era ripe for the perpetration of financial fraud. That makes it more important than ever for FINRA to have a holistic view of emerging trends and risks—and the ability to coordinate closely with other regulators and law enforcement. FINRA’s new National Cause and Financial Crimes Detection Programs (NCFC) will be the nerve center to do just that.May 26, 2020
Due to the coronavirus pandemic (COVID-19), FINRA is providing temporary relief for member firms from rules and requirements in the Frequently Asked Questions below. The relief provided does not extend beyond the identified rules and requirements. FINRA will continue to monitor the situation to determine whether additional guidance and relief may be appropriate. As coronavirus-related risks decrease, member firms should expect to return to meeting any regulatory obligations for which relief has been provided.March 24, 2020
- PodcastThe world of money laundering is a fast-paced and ever evolving, which can make it difficult for a financial firm to develop and maintain a strong anti-money laundering program. On this episode, two FINRA anti-money laundering experts discuss current priorities and best practices when it comes to AML regulation.May 14, 2019
- Compliance ToolsFINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering Program. The template provides language concerning, among other things, the final customer identification rule.July 18, 2018
- GuidanceComparison of the AML Customer Identification Rule and the SEC’s Books & Records Customer Account Records RuleTwo important regulatory developments relate to obtaining customer information: the Anti-Money Laundering Customer Identification Rule and the SEC's Books and Records Customer Account Records Rule. These rules require that important customer identification be obtained. However, these rules have critical differences including their purposes, their definitions, and their timing requirements. We created this document to assist our member firms. It contains brief summaries of the rules' relevant provisions.September 01, 2003
- GuidanceThis webcast focuses on what firms should expect from the Anti-Money Laundering reviews conducted as part of FINRA's routine examinations. We will review how FINRA examiners will check to make sure you have appropriate AML procedures in place, and you will learn what we expect of you and what you should expect from us during the AML part of an exam.
- FINRA Fines BNP Paribas Securities Corp. and BNP Paribas Prime Brokerage, Inc. $15 Million for AML Program and Supervisory FailuresOctober 24, 2019
- December 26, 2018
- December 17, 2018
- October 30, 2018
- FINRA Fines ICBCFS $5.3 Million for Anti-Money Laundering (AML) Compliance Deficiencies and Other ViolationsMay 16, 2018
- March 28, 2018
- FINRA Hearing Panel Fines C.L. King & Associates $750,000 for Negligent Misrepresentations and Omissions in Connection with Death Put Investments and AML-Related ViolationsSeptember 12, 2017
- FINRA Fines Credit Suisse Securities (USA) LLC $16.5 Million for Significant Deficiencies in its Anti-Money Laundering ProgramDecember 05, 2016
- May 18, 2016
- FINRA Decision Bars James Van Doren for Unethical Conduct; Registered Representative Engaged in Money Laundering and Assisted Friend in Deceiving CreditorsApril 25, 2016
- FINRA Sanctions Cantor Fitzgerald & Co. $7.3 Million for Selling Billions of Unregistered Microcap Shares, and for Related Supervisory and AML ViolationsDecember 21, 2015
- FINRA Expels Halcyon Cabot Partners and Bars CEO and CCO for Fraud, Sales Practice Abuses, and Widespread Supervisory and AML FailuresOctober 07, 2015
- August 03, 2015
- FINRA Sanctions LPL Financial LLC $11.7 Million for Widespread Supervisory Failures Related to Complex Products Sales, Trade Surveillance and Trade Confirmations DeliveryMay 06, 2015
- FINRA Fines Wells Fargo Advisors and Wells Fargo Advisors Financial Network $1.5 Million for Anti-Money Laundering FailuresDecember 18, 2014
- FINRA Charges Wedbush Securities for Systemic Market Access Violations, Anti-Money Laundering and Supervisory DeficienciesAugust 18, 2014
- FINRA Fines Brown Brothers Harriman A Record $8 Million for Substantial Anti-Money Laundering Compliance FailuresFebruary 05, 2014
- FINRA Fines Banorte-Ixe Securities $475,000 for Inadequate Anti-Money Laundering Program and for Failing to Register Foreign FindersJanuary 28, 2014
- December 16, 2013
- FINRA Fines Oppenheimer & Co., Inc. $1.4 Million for Sale of Unregistered Penny Stocks and Anti-Money Laundering ViolationsAugust 05, 2013
- May 08, 2013
- FINRA Joins Exchanges and the SEC in Fining Hold Brothers More Than $5.9 Million for Manipulative Trading, Anti-Money Laundering, and Other ViolationsSeptember 25, 2012
- April 04, 2011
- February 02, 2010
- October 26, 2009
- FINRA Expels Maximum Financial for Net Capital, AML, Other Violations While Engaging in Retail Foreign Currency Exchange BusinessAugust 18, 2009
- January 02, 2009
- GunnAllen Financial Pays $750,000 to Settle Charges Involving Former Head Trader's Trade Allocation Scheme, AML and Supervisory Deficiencies, Additional ChargesMay 08, 2008
- November 05, 2007