Westcott and Associates, Ltd., will assist in the preparation of the Anti-Money Laundering Procedures tailored to your firm’s specific needs.
The Procedures will coincide with the current AML Requirements and Template. It provides information about anti-money laundering (AML) rules, regulations, and compliance and will include AML Guidance, Education and Training and updates to the rules. We will assist periodically to reassess and update the AML Procedures.
Westcott and Associates, Ltd., will prepare an AML Program. The AML program is integral to the firm’s overall supervision and compliance program. AML has been a required part of every FINRA routine examination since 2002. This means that FINRA is responsible for reviewing a firm’s compliance with AML rules during routine exams regardless of firm size or business model. There are no exceptions to the requirement to have an AML program. The requirements apply to all FINRA firms regardless of size or business model, even if they do not hold customers.
Westcott and Associates, Ltd., will conduct an Independent AML Test of the AML Program Annually. The test of the AML Program must be in writing and include, at a minimum: Policies, Procedures, and internal controls reasonably designed to achieve compliance with BSA and it’s implementing rules. Policies and procedures should detect and cause the reporting of transactions and the implementing regulations and the designation of an AML compliance officer (AML Officer), including notification to the SROs and ongoing AML employee training.
For more information contact Westcott and Associates, Ltd., here or call (760) 632-1663.