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"... it is important that firm compliance programs evolve as well, to reflect the current business and organizational structure at a firm. And, those programs must keep pace with regulatory developments, market changes and industry standards. " |
Quote by
Mary L. Schapiro,
Chariman -
US Securities and Exchange Commission,
1/26/2010 |
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AML AUDIT SERVICES
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Independent testing of your AML compliance program is only one of the demands placed on broker dealers like yours, and it is one of the most important. FINRA requires that all member firms, regardless of their business or size, develop and implement an AML program reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act. The rule also requires that firms provide for independent testing for compliance by member personnel or by a qualified outside party.
Compliance Support Services is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS) and holds the Certified AML Specialist (CAMS)certification awarded to professionals who successfully complete a rigorous examination demonstrating their aptitude and expertise in anti-money laundering detection and enforcement. Compliance Support Services also satisfies the definition of "independent" defined in FINRA Rule 3310.01(b) enabling us to conduct your AML program audit within the rule requirements.
The audit process includes:
- A thorough review of your AML program document that outlines your firm’s processes and procedures with respect to anti-money laundering.
- An onsite examination of exception reports, BSA report filings, FinCEN files, Customer Identification Program records, results of pervious AML audits and any other AML files required for the firm's business activities.
- A review of previous SEC and FINRA examination results to be sure all deficiencies with respect to AML have been addressed and updated.
- Production of a written audit report that outlines the results of the audit and offers recommendations to improve or update the program as necessary, along with a letter to senior management introducing the report.
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