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ARTICLE · 06 APRIL 2018

FINRA Updates AML Template For Small Firms

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FINRA revised the template that small firms registered with FINRA may use in developing anti-money laundering ("AML") programs.

United StatesGovernment, Public Sector
Christian Larson
Christian Larson
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FINRA revised the template that small firms registered with FINRA may use in developing anti-money laundering ("AML") programs. The changes to the template reflect the Financial Crimes Enforcement Network's ("FinCEN") final rule on customer due diligence requirements for financial institutions ("CDD Rule").

The CDD Rule requires financial institutions, including FINRA member firms, to identify the individual beneficial owners of legal entity customers opening new accounts. FINRA Rule 3310 requires FINRA member firms write and implement AML programs to comply with the Bank Secrecy Act. As previously covered, FinCEN's CDD Rule goes into effect on May 11, 2018.

Commentary / Christian Larson

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