The requirements of building an effective AML program can be found within many US Rules and Regulations. While having a robust AML program is key, it is equally critical to adhere to the controls and oversight set forth within the program. Recently, an AML Compliance Officer found out just how critical following procedures is when faced with FINRA charges regarding improper supervision of the firm’s AML program.
FINRA determined that the Compliance Officer failed to adhere to many of the requirements set forth in FINRA Rules 3310(a) and 3310 (b) which specifically mandate that firms establish internal controls reasonably designed to achieve compliance with the Bank Secrecy Act. While regulators continue to modify and institute new guidelines around AML, the trend of holding individuals accountable continues to accelerate. CCOs and AML Heads should ensure there are QA processes, and targeted metrics in place to ensure gaps in procedures or aging alerts are properly identified and addressed.
