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ARTICLE · 20 APRIL 2021

Broker-Dealer Settles FINRA Charges For Inadequate AML Program

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A broker-dealer settled FINRA charges for failing to implement an AML program tailored to the broker-dealer's retail business.

United StatesGovernment, Public Sector
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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A broker-dealer settled FINRA charges for failing to implement an AML program tailored to the broker-dealer's retail business.

In a Letter of Acceptance, Waiver, and Consent, FINRA alleged that the broker-dealer's AML procedures did not:

  • include a risk-based customer identification program tailored to its customer base;
  • discuss any exception reports that could be used for the identification of suspicious transaction red flags;
  • provide a description of how to perform additional monitoring for accounts in which suspicious trading was detected;
  • explain the manner and frequency in which foreign accounts should be monitored; or
  • include any policies regarding the documentation of its investigations into potentially suspicious activity.

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