Anti-Money Laundering (AML)

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 under FINRA 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.

1. The program has to be approved in writing by a senior manager.
2. It must be reasonably designed to ensure the firm detects and reports suspicious activity.
3. 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.
4. It must be independently tested to ensure proper implementation of the program.
5. Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).
6. Ongoing training must be provided to appropriate personnel.
7. 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 an Anti-Money Laundering Template to assist Small Firms in establishing the AML compliance program required by the Bank Secrecy Act, its implementing regulations, and FINRA Rule 3310.

Frequently Asked Questions

Find answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.

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.

Contact OGC

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 Rules for more information.

OGC staff contacts:

Victoria Crane
Tom Kimbrell
FINRA, OGC
1700 K Street, NW
Washington, DC 20006
(202) 728-8000