Broker-Dealer Fined for Failing to Test AML Compliance Program

A broker-dealer settled FINRA charges for failing to properly test the firm's AML compliance program.

In a Letter of Acceptance, Waiver, and Consent, FINRA found that the broker-dealer failed to conduct sufficient annual testing of its AML compliance program, as required. The broker-dealer had contracted an outside audit firm to conduct the test, and despite the auditor confirming that the broker-dealer's cash disbursements and its written AML policies were reviewed, the auditor did not assess the adequacy of the broker-dealer's program or its compliance with its own policies.

As a result, FINRA determined that the broker-dealer violated FINRA Rule 2010 ("Standards of Commercial Honor and Principles of Trade") and Rule 3310(c) ("Anti-Money Laundering Compliance Program"). To settle the charges, the broker-dealer agreed to a $5,000 civil monetary penalty.