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 (www.acams.org), 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 http://www.acams.org/free-webinar-library/. The panel has also created their own set of FAQs which you can find under the Attachment tab.