Anti-Money Laundering (AML)
Firms must comply with the Bank Secrecy Act and its implementing regulations ("Anti-Money Laundering 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.
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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. The template provides text examples, instructions, relevant rules and Web sites, and other resources.
Anti-Money Laundering Forms
- 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) Line Item Electronic Filing Instructions (must be filed electronically through the BSA E-Filing System)
- Report of International Transportation of Currency or Monetary Instruments (CMIR)
- Blocked Properties Reporting Form (OFAC)
- Voluntary Form for Reporting Blocked Transactions (OFAC)
- Voluntary Form for Reporting Rejected Transactions (OFAC)
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.
Visit our e-learning courses page to learn more.
AML Half-Day Seminars
FINRA’s AML Half-Day Seminars provide attendees with information on the fundamentals of money laundering and money laundering typologies, relevant rules and regulations, and monitoring for suspicious activity. Each seminar provides demonstrations on using data and publicly available information to supplement compliance reviews of exception reports and alerts generated by automated surveillance systems.
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 contact:
1735 K Street, NW
Washington, DC 20006
- FINRA Reminds Firms to Beware of Fraud During the Coronavirus (COVID-19) Pandemic
- FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
- FINRA Amends Rule 3310 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
- 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: *
- SEC Requests Broker-Dealers Make SARs and SAR Information Available to FINRA
- SEC Approval and Effective Dates for New Consolidated FINRA Rules
- NASD and NYSE Joint Release Regarding Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
- Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
- SEC Approves Amendments to Anti-Money Laundering Compliance Program Rule and Adoption of Interpretive Material
- Treasury and SEC Issue Final Rule Regarding Customer Identification Programs for Broker/Dealers
- Development Regarding Treasury Information Requests Under Section 314 of the PATRIOT Act
- NASD Adopts Amendments to Rule 3011 to Require Members to Provide to NASD Contact Information for an Anti-Money Laundering Compliance Person(s)
- Treasury and SEC Request Comment on Proposed Regulation Regarding Broker/Dealer Anti-Money Laundering Customer Identification Requirements
- Treasury Issues Final Suspicious Activity Reporting Rule for Broker/Dealers
- NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law
- Executive Order Targeting Terrorists
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
- 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
Following the terrorist attacks of September 11, 2001, Congress passed the USA PATRIOT Act, in part, to strengthen the anti-money laundering (AML) and counter-terrorist financing provisions of the Bank Secrecy Act (BSA) and extend them to broker-dealers. Among other provisions, the BSA requires firms to monitor for, detect and report suspicious activity to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN).December 01, 2017
- 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
- FAQFor further information on Anti-Money Laundering requirements, please visit the FINRA Anti-Money Laundering (AML) page.
- 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