Reinforcing the need to implement strong AML controls, FINRA issued a Notice to Members encouraging firms to begin incorporating FinCEN’s recently issued AML/CFT Priorities into their AML programs.
FINRA highlighted the need to update AML ‘red flags’ to include factors such as customers’ business activities, size, the geographic locations in which they operate, the types of accounts they maintain, and the types of transactions in which they engage. FINRA also encouraged firms to consider any technological changes needed to incorporate the AML/CFT Priorities. However, CCOs should be very diligent in evaluating potential vendor products. Many of the most popular (and highly funded) vendor solutions lack the functionality needed to implement FinCEN’s priorities.
