The SEC’s Division of Examinations is continuing to stress the importance of AML and BSA compliance. If you haven’t seen it, the Division issued a Risk Alert in late March highlighting AML deficiencies it identified in their reviews of broker-dealers and mutual funds. Inadequate AML Policies and Procedures, along with the failure to properly implement those procedures, were high on their list of findings.
In addition, the Division identified issues in filing incorrect or incomplete SARs. And, yet again, firms were dinged for “unreasonably” relying on a manual review of transactions rather than implementing an automated system to monitor and report suspicious activity. You can access the Alert here.