FINRA encouraged members to incorporate FinCEN's published AML priorities into broker-dealer compliance programs. FinCEN issued its Anti-Money Laundering / Combating the Financing of Terrorism ("AML/CFT") priorities in accordance with the Anti-Money Laundering Act of 2020.
FINRA reminded firms that FINRA Rule 3310 ("Anti-Money Laundering Compliance Program") requires firm compliance with the Bank Secrecy Act (or "BSA"). FINRA advised firms to consider how the priorities match up with their risk-based AML programs. FINRA suggested that firms begin their evaluation by (i) reviewing red flags based on their business activities, size and location and (ii) considering potential technological changes that would assist in a firm's AML program.