Compliance Support Services

AML Audit 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.




Independent testing of your AML compliance program is only one of the demands placed on broker dealers like yours, and it is one of the most important. FINRA requires that all member firms, regardless of their business or size, develop and implement an AML program reasonably designed to achieve compliance with the requirements of the Bank Secrecy Act. The rule also requires that firms provide for independent testing for compliance by member personnel or by a qualified outside party.

Compliance Support Services is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS) and holds the Certified AML Specialist (CAMS) certification awarded to professionals who successfully complete a rigorous examination demonstrating their aptitude and expertise in anti-money laundering detection and enforcement. Compliance Support Services also satisfies the definition of "independent" defined in FINRA Rule 3310.01(b) enabling us to conduct your AML program audit within the rule requirements. The audit process includes:

  • A thorough review of your AML program document that outlines your firm’s processes and procedures with respect to anti-money laundering.
  • An onsite examination of exception reports, BSA report filings, FinCEN files, Customer Identification Program records, results of pervious AML audits and any other AML files required for the firm's business activities.
  • A review of previous SEC and FINRA examination results to be sure all deficiencies with respect to AML have been addressed and updated.
  • Production of a written audit report that outlines the results of the audit and offers recommendations to improve or update the program as necessary, along with a letter to senior management introducing the report.


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