Independent AML Testing

FINRA Rule 3310 requires broker-dealers to comply with the Bank Secrecy Act and its implementing regulations ("AML Rules"). It also sets forth minimum standards for a firm’s written AML compliance program.

1. The program has to be approved in writing by a senior manager.

2. It must be reasonably designed to ensure the firm detects and reports suspicious activity.

3. 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.

4. It must be independently tested to ensure proper implementation of the program.

5. Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).

6. Ongoing training must be provided to appropriate personnel.

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Cerulean specializes in conducting independent anti-money laundering testing that will help you detect and address weaknesses and deficiencies in your AML compliance program. Each independent AML test is conducted by a Certified Anti-Money Laundering Specialist (CAMS). Cerulean will thoroughly review your AML compliance program, deliver a written report that discusses the findings and make recommendations for improvement as needed.

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For additional information, please see the Anti-Money Laundering section of our Resources page.