Keynote Address at the SIFMA Anti-Money Laundering Seminar
March 3, 2011
In a recent speech before SIFMA's Anti-Money Laundering Seminar, OCIE Director Carlo V. di Florio addressed (i) general developments at the SEC; (ii) changes to OCIE's national exam program, and (iii) anti-money laundering issues of concern. With respect to AML examination issues, Mr. di Florio stressed, among other things, AML concerns as to (i) direct market access, and (ii) master-sub accounts. Mr. di Florio also highlighted a few recent AML enforcement actions and other regulatory developments.
Cross References
In re Ronald S. Bloomfield, SEC Release No. 34-61988 (Apr. 27, 2010) (AML enforcement action)
SIFMA No-Action Letter (Jan. 11, 2011) (re. IA performance of CIP obligations)
FinCEN: Multi-Agency Guidance on Beneficial Ownership (Mar. 5, 2010)