ANTI-MONEY LAUNDERING PROCEDURES

AML Compliance Program

The USA PATRIOT Act of 2001 requires that all securities firms establish an Anti-Money Laundering Compliance Program to prevent and detect the act of money laundering. To meet the requirements of the PATRIOT Act, FINRA set forth Rule 3011 which establishes the requirements that all FINRA member firms must meet in order to have a compliant anti-money laundering program.

1. Establish and implement policies and procedures in order to detect and report suspicious activities or suspicious transactions;
2. Establish and implement policies and procedures in order for the firm to achieve compliance with the anti-money laundering and the BSA requirements;
3. Design a program to independently test the firm for compliance to the firm's Anti-Money Laundering Program;
4. Designate an individual(s) to be responsible for the day-to-day monitoring of the firm's Anti-Money Laundering Compliance Program; and
5. Provide anti-money laundering training to the firm's personnel.

Contact BCG today to discuss how we can help your firm develop a compliant Anti-Money Laundering Program. If you already have an AML program in place, BCG can review and access the adequacy of your current program. Call BCG to discuss your specific needs or to request a proposal.

As part of your firm's overall Anti-Money Laundering Compliance Program, your firm is required to create, maintain and enforce a Customer Identification Program. This program sets forth the requirements for the identification of customers and the verification of that identification.

BCG will create a separate Customer Identification Program for you to implement at your firm. Contact BCG for more information, to get answers to your questions or to request a quote for the creation of Customer Identification Program designed specifically for your firm.

Each securities firm is required to annually review and test the adequacy of the firm's Anti-Money Laundering Compliance Program. The audit must be conducted by an independent party (independent internal personnel or an outside vendor, like BCG) and findings must be reported to senior management of the firm.

To ensure the independence of your auditors, engage BCG to perform the test of your Anti-Money Laundering Compliance Program. Give us a call today to discuss your needs and/or request a proposal.