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Certainly, the test for all firms is whether they maintain and each day, reinforce, a culture of compliance — which includes a culture of doing not only what is within the strict parameters of the law, but also what is right — whether or not a regulator or anyone else is looking. " |
Quote by
Lori Richards,
Director -
SEC,
4/23/2003 |
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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 its likely 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 the program is tested by an outside independent party.
Compliance Support Services is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS) and holds the 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 IM-3011-1(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, and any other AML files the Firm is required to retain pursuant to the rule, as well as results of previous AML audits.
- 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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