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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
Both the previous and updated versions of FINRA's AML Program template state that the template is provided "only as a helpful starting point" and that "following the template does not guarantee compliance" with AML program requirements. Firms that have relied upon the previous template should update their AML programs to implement the new CDD rule by the May 11 go-live date. FINRA's updated template provides helpful information, but each FINRA member should ensure that its AML program addresses the specific money laundering risks the firm faces.
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