Compliance Support Services

Compliance Services

last modified: 27 Oct 2017
page manager: compliancess

October 27, 2017

With November 1st around the corner, the end of the year quickly follows. Have you had your AML audit for the year, or at least scheduled? If not, be sure to contact your AML auditor next week. If you are a small limited purpose broker dealer in need of your 2017 AML audit. Specializing in limited purpose broker dealer requirements, we can take this one end of year “to do” off your list, but don’t delay. Call 215-493-1559 to speak with us.

The new year will also bring the new enhanced due diligence requirements for capturing the beneficial owner (read beating heart) of legal entity customers. Scroll down to read the FIN-2-G003 for more information.

September 11, 2017

My thoughts and prayers go out to my clients and colleagues in Florida, Georgia and Alabama as you join Texas in recovering from Mother Nature’s wrath. I hope you and your loved ones are safe.



Guidance to Members
FINRA published Regulatory Notice 17-27 last week in response to Hurricane Harvey, although the Notice most certainly goes for Irma as well. Comparing this notice to 12-45 which was posted after Sandy, you’ll see that the information has been expanded to include communications requirements and other considerations. Even if your firm was not affected by either event, it is worth taking a look at your business continuity plan and adding to it based on this guidance. If you recall, there weren’t so many of these massive natural disasters back when the original rule was passed, so it shouldn’t be a surprise when FINRA updates the template in the near future.

Beneficial Ownership and Customer Due Diligence
The Beneficial ownership and enhanced customer due diligence requirements implementation date is fast approaching. In addition to the numerous documents describing the new requirements you can find on an internet search, pay particular attention to the FAQ issued by FinCEN on July 19, 2016 in FIN-2-16-G003.

If you are still unclear about how you are going to approach the new requirements, listen to a webinar hosted by ACAMS (, the largest international AML and financial crime prevention community. The free webinar discusses the panel’s thoughts about their plans to implement the new rule as applicable to their business. While these folks represent the banking side, their ideas can apply to your business model. Access ”The CDD Final Rule: Responding Effectively to Implementation Hurdles” (May 12, 2017) at The panel has also created their own set of FAQs which you can find under the Attachment tab.




Compliance is an ever-changing landscape. What stays the same is Compliance Support Services' commitment to you and your regulatory compliance program. Our services include, but are not limited to:

  • Prepare and update your Compliance Calendar so you don't miss any regulatory filing dates.
  • Interpret new regulations applicable to your business into practical processes and procedures.
  • Evaluate your existing compliance system in relation to current regulatory requirements relevant to your business to make sure your procedures and processes are in line with regulatory expectations.
  • Review your Written Supervisory Procedures to ensure they are up-to-date and relevant to your business model.
  • Develop Representative Compliance and Supervisory Manuals as needed.
  • Assist in completing the test and certification reports required by Rules 3012 and 3130.
  • Evaluate your Continuing Education Program and provide a needs analysis and training plan along with suggested courses and training opportunities.
  • Conduct the annual Home Office OSJ audit and annual review of your business pursuant to Rule 3010.
  • Prepare the Firm for regulatory exams.
  • Prepare the application required by Rule 1017 to lift a restriction, add a new business line or other change to your currently approved business activities.
  • Conduct branch audits on a limited basis.

For New Broker Dealers
Remember all the compliance information you received during your pre-membership interview? Not sure how you develop your system of supervision, prepare for your first FINRA examination, or what steps to take now that you are a member? Compliance Support Services can help. Complete the Contact form for more information today.