Firms must comply with the Bank Secrecy Act and its implementing regulations ("AML rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation.
FINRA reviews a firm’s compliance with AML rules underFINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program. The basic tenets of an AML compliance program under FINRA 3310 include the following.
- The program has to be approved in writing by a senior manager.
- It must be reasonably designed to ensure the firm detects and reports suspicious activity.
- It must be reasonably designed to achieve compliance with the AML Rules, including, among others, having a risk-based customer identification program (CIP) that enables the firm to form a reasonable belief that it knows the true identity of its customers.
- It must be independently tested to ensure proper implementation of the program.
- Each FINRA member firm must submit contact information for its AML Compliance Officer through theFINRA Contact System (FCS).
- Ongoing training must be provided to appropriate personnel.
- The program must include appropriate risk-based procedures for conducting ongoing customer due diligence, including (i) understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and, (ii) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, including information regarding the beneficial owners of legal entity customers.
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Anti-Money Laundering Template for Small Firms
FINRA provides anAnti-Money Laundering Templateto assist Small Firms in establishing the AML compliance program required by the Bank Secrecy Act, its implementing regulations, and FINRA Rule 3310.
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Frequently Asked Questions
Find answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.
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AML Reports and Systems
- Suspicious Activity Report (SAR) (must be filed electronically through the BSA E-Filing System)
- Currency Transaction Report (CTR) (must be filed electronically through the BSA E-Filing System)
- Report of Foreign Bank and Financial Accounts (FBAR) (FinCEN 114) (must be filed electronically through the BSA E-Filing System)
- Report of International Transportation of Currency or Monetary Instruments (CMIR)
- Section 314(a) Secure Information Sharing System
- OFAC Reporting System for Blocked and Rejected Transactions
E-Learning
FINRA's Anti-Money Laundering (AML) e-learning courses cover concepts and strategies for detecting and preventing money-laundering activity. Each course presents unique scenarios that illustrate typical money-laundering situations.
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ContactOGC
FINRA's Office of General Counsel (OGC) staff provides broker-dealers, attorneys, registered representatives, investors and other interested parties with interpretative guidance relating to FINRA’s rules. Please see Interpreting FINRA Rulesfor more information.
OGC staff contacts:
Victoria Crane
Tom Kimbrell
FINRA, OGC
1700 K Street, NW
Washington, DC 20006
(202) 728-8000
Capital Acquisition Broker Rules
331. Anti-Money Laundering Compliance Program
FINRA Rules
3310. Anti-Money Laundering Compliance Program
Regulatory Notice 21-03
FINRA Urges Firms to Review Their Policies and Procedures Relating to Red Flags of Potential Securities Fraud Involving Low-Priced Securities
02/10/2021
Regulatory Notice 20-13
FINRA Reminds Firms to Beware of Fraud During the Coronavirus (COVID-19) Pandemic
05/05/2020
Regulatory Notice 19-18
FINRA Provides Guidance to Firms Regarding Suspicious Activity Monitoring and Reporting Obligations
05/06/2019
Regulatory Notice 18-36
FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
10/19/2018
Regulatory Notice 18-19
FINRA Amends Rule 3310 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
05/03/2018
Regulatory Notice 17-40
FINRA Provides Guidance to Firms Regarding Anti-Money Laundering Program Requirements Under FINRA Rule 3310 Following Adoption of FinCEN's Final Rule to Enhance Customer Due Diligence Requirements for Financial Institutions Effective Date: *
11/21/2017
Regulatory Notice 12-08
SEC Requests Broker-Dealers Make SARs and SAR Information Available to FINRA
02/10/2012
Regulatory Notice 09-60
SEC Approval and Effective Dates for New Consolidated FINRA Rules
10/15/2009
Notice to Members 07-17
NASD and NYSE Joint Release Regarding Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
04/18/2007
Notice to Members 06-41
Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
08/14/2006
Notice to Members 06-07
SEC Approves Amendments to Anti-Money Laundering Compliance Program Rule and Adoption of Interpretive Material
02/10/2006
Notice to Members 03-34
Treasury and SEC Issue Final Rule Regarding Customer Identification Programs for Broker/Dealers
06/20/2003
Notice to Members 02-80
Development Regarding Treasury Information Requests Under Section 314 of the PATRIOT Act
12/02/2002
Notice to Members 02-78
NASD Adopts Amendments to Rule 3011 to Require Members to Provide to NASD Contact Information for an Anti-Money Laundering Compliance Person(s)
10/31/2002
Notice to Members 02-50
Treasury and SEC Request Comment on Proposed Regulation Regarding Broker/Dealer Anti-Money Laundering Customer Identification Requirements
08/13/2002
Notice to Members 02-47
Treasury Issues Final Suspicious Activity Reporting Rule for Broker/Dealers
08/12/2002
Notice to Members 02-21
NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law
04/10/2002
Notice to Members 01-67
Executive Order Targeting Terrorists
10/10/2001
FAQ
Frequently Asked Questions (FAQ) regarding Anti-Money Laundering (AML)
Answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.
Guidance
Anti-Money Laundering, Fraud and Sanctions
The Anti-Money Laundering, Fraud and Sanctions topic of the 2024 FINRA Annual Regulatory Oversight Report (the Report) informs member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations, including (1) regulatory obligations and related considerations, (2) findings and effective practices, and (3) additional resources.
January 09, 2024
Media Center
AML Update: The Latest Trends and Effective Practices
Money laundering looks different in the securities industry and that poses its own challenges. Add to that a landscape of constantly evolving threats and it is a lot to keep up with. On this episode, we hear about emerging threats and how firms can ensure their AML program remains strong and effective.
May 31, 2022
Guidance
Sanctions Alert: Russia-Related Sanctions
The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection (NCFC) program is bringing to your attention some additional Russia-related sanctions developments. Please note that these are in addition to those detailed inFINRA Regulatory Notice 22-06.
February 28, 2022
Podcast
Overlapping Risks, Part 2: Anti-Money Laundering and Elder Exploitation
A broker-deal firm’s anti-money laundering efforts may overlap with any number of other regulatory concerns. On this episode, the second in a two-part series, we’re looking at how AML may overlap with a firm’s efforts to protect senior investors from exploitation and fraud.
November 10, 2020
Podcast
Overlapping Risks, Part 1: Anti-Money Laundering and Cybersecurity
Firm regulatory risks and priorities don't exist in a vacuum. And that is perhaps nowhere clearer than when it comes to a firm's anti-money laundering responsibilities. A firm's AML risks can overlap with any number of other priorities. On this episode, the first of a two-part series, we look at the overlapping risks of AML and cybersecurity.
October 27, 2020
Podcast
Encore | Beyond Hollywood: Money Laundering in the Securities Industry
This episode originally aired in April 2019.The only thing many people know about money laundering is what they’ve learned from Hollywood. So if you want to really understand what money laundering is, and more specifically, the efforts brokerage firms must take to prevent and detect it, tune in. On this episode we talk to two of FINRA’s Anti-Money Laundering experts.
August 04, 2020
Virtual Conference Panel
Financial Crimes, Trends and Responses – In the Midst of the Pandemic
COVID-19 has altered the world as we know it. While some have responded to it as an incident or singular event, in the world of countering criminal threats we are seeing the need to treat it as a sustained campaign. This panel will discuss the multitude of threats across the financial crimes’ spectrum perpetrated by an aggressive yet flexible adversary.
June 09, 2020
Podcast
Introducing Greg Ruppert and the National Cause and Financial Crimes Detection Programs
Between the level of interconnectedness on the web and the sheer about of data available, we’re living in an era ripe for the perpetration of financial fraud. That makes it more important than ever for FINRA to have a holistic view of emerging trends and risks—and the ability to coordinate closely with other regulators and law enforcement. FINRA’s new National Cause and Financial Crimes Detection Programs (NCFC) will be the nerve center to do just that.
May 26, 2020
FAQ
Frequently Asked Questions Related to Regulatory Relief Due to the Coronavirus Pandemic
Due to the coronavirus pandemic (COVID-19), FINRA is providing temporary relief for member firms from rules and requirements in the Frequently Asked Questions below. The relief provided does not extend beyond the identified rules and requirements. FINRA will continue to monitor the situation to determine whether additional guidance and relief may be appropriate.As coronavirus-related risks decrease, member firms should expect to return to meeting any regulatory obligations for which relief has been provided.
March 24, 2020
Podcast
Beyond Hollywood, Part II: AML Priorities and Best Practices
The world of money laundering is a fast-paced and ever evolving, which can make it difficult for a financial firm to develop and maintain a strong anti-money laundering program. On this episode, two FINRA anti-money laundering experts discuss current priorities and best practices when it comes to AML regulation.
May 14, 2019
Compliance Tools
Anti-Money Laundering (AML) Template for Small Firms
FINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering Program. The template provides language concerning, among other things, the final customer identification rule.
July 18, 2018
Guidance
Two important regulatory developments relate to obtaining customer information: the Anti-Money Laundering Customer Identification Rule and the SEC's Books and Records Customer Account Records Rule. These rules require that important customer identification be obtained. However, these rules have critical differences including their purposes, their definitions, and their timing requirements. We created this document to assist our member firms. It contains brief summaries of the rules' relevant provisions.
September 01, 2003
Guidance
What to Expect: Anti-Money Laundering Reviews During Routine Examinations
This webcast focuses on what firms should expect from the Anti-Money Laundering reviews conducted as part of FINRA's routine examinations. We will review how FINRA examiners will check to make sure you have appropriate AML procedures in place, and you will learn what we expect of you and what you should expect from us during the AML part of an exam.
FINRA Fines BNP Paribas Securities Corp. and BNP Paribas Prime Brokerage, Inc. $15 Million for AML Program and Supervisory Failures
October 24, 2019
FINRA Fines Morgan Stanley $10 Million for AML Program and Supervisory Failures
December 26, 2018
FINRA Fines UBS $5 Million for Significant Deficiencies in Anti-Money Laundering Programs
December 17, 2018
FINRA Fines LPL $2.75 Million for Complaint-Reporting and AML Program Failures
October 30, 2018
FINRA Fines ICBCFS $5.3 Million for Anti-Money Laundering (AML) Compliance Deficiencies and Other Violations
May 16, 2018
FINRA Fines Aegis Capital Corp. $550,000 for Anti-Money Laundering and Supervision Rule Violations
March 28, 2018
September 12, 2017
FINRA Fines Credit Suisse Securities (USA) LLC $16.5 Million for Significant Deficiencies in its Anti-Money Laundering Program
December 05, 2016
FINRA Fines Raymond James $17 Million for Systemic Anti-Money Laundering Compliance Failures
May 18, 2016
FINRA Decision Bars James Van Doren for Unethical Conduct; Registered Representative Engaged in Money Laundering and Assisted Friend in Deceiving Creditors
April 25, 2016
December 21, 2015
FINRA Expels Halcyon Cabot Partners and Bars CEO and CCO for Fraud, Sales Practice Abuses, and Widespread Supervisory and AML Failures
October 07, 2015
FINRA Fines Aegis Capital Corp. $950,000 for Sales of Unregistered Penny Stocks and AML Violations
August 03, 2015
FINRA Sanctions LPL Financial LLC $11.7 Million for Widespread Supervisory Failures Related to Complex Products Sales, Trade Surveillance and Trade Confirmations Delivery
May 06, 2015
FINRA Fines Wells Fargo Advisors and Wells Fargo Advisors Financial Network $1.5 Million for Anti-Money Laundering Failures
December 18, 2014
FINRA Charges Wedbush Securities for Systemic Market Access Violations, Anti-Money Laundering and Supervisory Deficiencies
August 18, 2014
FINRA Fines Brown Brothers Harriman A Record $8 Million for Substantial Anti-Money Laundering Compliance Failures
February 05, 2014
FINRA Fines Banorte-Ixe Securities $475,000 for Inadequate Anti-Money Laundering Program and for Failing to Register Foreign Finders
January 28, 2014
FINRA Fines COR Clearing LLC $1 Million for Extensive Regulatory Failures
December 16, 2013
August 05, 2013
FINRA Fines Three Firms $900,000 for Inadequate Anti-Money Laundering Programs
May 08, 2013
FINRA Joins Exchanges and the SEC in Fining Hold Brothers More Than $5.9 Million for Manipulative Trading, Anti-Money Laundering, and Other Violations
September 25, 2012
FINRA Hearing Panel Expels AIS Financial, Inc. for Systemic Anti-Money Laundering Violations
April 04, 2011
FINRA Fines Firms $750,000 for Inadequate Anti-Money Laundering Programs, Other Violations
February 02, 2010
Scottrade Fined $600,000 for Inadequate Anti-Money Laundering Program
October 26, 2009
FINRA Expels Maximum Financial for Net Capital, AML, Other Violations While Engaging in Retail Foreign Currency Exchange Business
August 18, 2009
E*Trade Units Fined $1 Million for Inadequate Anti-Money Laundering Program
January 02, 2009
GunnAllen Financial Pays $750,000 to Settle Charges Involving Former Head Trader's Trade Allocation Scheme, AML and Supervisory Deficiencies, Additional Charges
May 08, 2008
FINRA Expels Franklin Ross, Inc. for Systemic Violations of Anti-Money Laundering Rules
November 05, 2007
Investor Education
Customer Identification Program Notice
Important Information You Need to Know about Opening a New Account
