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Anti-Money Laundering

Important Information

FinCEN publishes important advisories with detailed information about a variety of money laundering threats.  These advisories should be reviewed on a regular basis to ensure that you take advantage of the information provided as appropriate.

FinCEN Suggestions for Addressing Common Errors Noted in Suspicious Activity Reports (SARs)

FINRA AML Small Firm Template

FinCEN Guidance on Suspicious Activity Reports (SARs) Supporting Documentation
Clarifies the Bank Secrecy Act requirement that financial institutions provide SAR supporting documentation to FinCen and appropriate law enforcement or supervisory agencies.
 
Submit AML Compliance Officer Contact Information to FINRA Contact System (FCS)
Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).

 
Customer Identification Program Notice
FINRA has produced the Customer Identification Program (CIP) Notice to assist firms with this notification requirement. This CIP Notice replaces the FINRA AML Statement Stuffer. FINRA will print the CIP Notice in bulk at the member's cost. Please send us an email to order this notice.

AML Guidance

• The SAR Activity Review – Trends, Tips & Issues, Issue 13 (May 2008)

• FinCen Guidance:   Frequently Asked Questions – Anti-Money Laundering Program and Suspicious Activity Reporting Requirements for Insurance Companies (March 20, 2008)
• FinCen Guidance (PDF 99 KB):  Guidance to Financial Institutions on Filing Suspicious Activity Reports regarding the Proceeds of Foreign Corruption (April 17, 2008)
• FinCEN Guidance: Application of Correspondent Account Rules to the Presentation of Negotiable Instruments Received by a Covered Financial Institution for Payment (January 30, 2008)
• Anti-Money Laundering Frequently Asked Questions

• SEC and FinCEN re-extend no-action letter relief for CIP reliance upon investment advisers.

• FinCen Guidance: Guidance on Application of the Correspondent Account Rule to Executing Dealers Operating in Over-The-Counter Foreign Exchange and Derivatives Markets Pursuant to Prime Brokerage Arrangements (September 5, 2007)

• Treasury Department guidance on the application final rules implementing section 312 of the USA PATRIOT Act.

• Joint SEC and Treasury guidance on CIP program responsibilities under the Agency Lending Disclosure Initiative.
• Joint CFTC and Treasury guidance on the application of the CIP rule for futures commission merchants and introducing brokers.
• Comparison of the AML Customer Identification Rule and the SEC Books & Records Customer Account Records Rule
• Financial Crimes Enforcement Network (FinCEN) is the Bureau of the US Department of the Treasury responsible for the administration of the Bank Secrecy Act. 
• Guidance clarifying the date on which certain U.S. financial institutions must complete Foreign Bank Re-certifications under 31C.F.R. Section 103.177.
• Guidance confirming that securities broker-dealers, futures commission merchants, and introducing brokers in commodities may share Suspicious Activity Reports with parent entities, both domestic and foreign.
• Section 314(a) Facts and Figures: FinCEN frequently publishes valuable information about the benefit to law enforcement of its Rule 314(a) requests for information.
• The SAR Activity Review, By the Numbers, Issue 8 (June 2007)
• The SAR Activity Review - Trends, Tips & Issues, Issue 11 (May 2007)
• Law Enforcement Cases Supported by BSA Filings
• Guidance on Preparing a Complete and Sufficient Suspicious Activity Report Narrative (Nov. 2003)
• Preparation Guidelines for Suspicious Activity Report Form (SAR), June 2000 (SAR Guidelines)
• Guidance on Application of the Customer Identification Program Rule to Futures Commission Merchants Operating as Executing and Clearing Brokers in Give-Up Arrangements (April 20, 2007)
• Section 311 Special Measures: Under Section 311 of the USA PATRIOT Act, the Secretary of the Treasury can designate particular jurisdictions or financial institutions to be of “primary money laundering concern.”
• Money Laundering: A Banker’s Guide to Avoiding Problems.
  Office of the Comptroller of the Currency (2002)
• American Bankers Association Resource Guide: Identification and Verification of Account Holders
• AML Examination Handbook issued by the five federal banking regulators
  
  
• Financial Action Task Force (FATF)
• • FATF Non-Cooperative Territories and Countries
  • FATF Money Laundering and Terrorist Financing Typologies (2004 - 2005)
  • FATF Guidance on the Risk-Based Approach to Combating Money Laundering and Terrorist Financing
    
    
• The Office of Foreign Assets Control (OFAC), a Bureau of the Treasury Department, The Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction. OFAC acts under Presidential wartime and national emergency powers, as well as authority granted by specific legislation, to impose controls on transactions and freeze foreign assets under US jurisdiction.
• • Foreign Assets Control Regulations for the Securities Industry
  • Recent OFAC Actions

News

• Bank Secrecy Act Obligations of a U.S. Clearing Broker-Dealer Establishing a Fully Disclosed Clearing Relationship with a Foreign Financial Institution

• Customer Identification Program Rule No-Action Position Respecting Broker-Dealers Operating Under Fully Disclosed Clearing Agreements According to Certain Functional Allocations

• Banks AML Examination Manual: Federal Financial Institutions Examination Council AML Examination Manual
• The Financial Crimes Enforcement Network (FinCEN) Issues Final Rule for Special Due Diligence Programs for Certain Foreign Accounts

Tools

• OFAC Search Tool enables searches of the U.S. Treasury's Office of Foreign Asset Control's (OFAC) Sanctions Program Listings

AML Rules & Regulations

• NASD AML Rule 3011
• • AML Compliance Programs (SEC Approval Order)
    
    
• Incorporated NYSE Member Regulation Rule 445 (PDF, scroll down to "Rule 445. Anti-Money Laundering Compliance Program")
• USA PATRIOT Act
• U.S. Treasury Department Rules
• MSRB Final Rule G-41

Regulatory Notices

• 07-17 NASD and NYSE Joint Release Regarding Special Measures against specified Banks Pursuant to Section 311 of the USA Patriot Act.
• 06-41 NASD and NYSE Joint Release on Section 311 of the USA PATRIOT Act. Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act.
• 06-07 SEC Approves Amendments to Anti-Money Laundering Program Compliance Rule and Adoption of Interpretive Material; Effective Date: March 6, 2006
• 03-34 Treasury and SEC Issue Final Rule Regarding Customer Identification Programs for Broker/Dealers; Effective Date: October 1, 2003
• 02-80 Development Regarding Treasury Information Requests Under Section 314 of the PATRIOT Act
• 02-78 NASD Adopts Amendments to Rule 3011 to Require Members to Provide to NASD Contact Information for an Anti-Money Laundering Compliance Person(s)
• 02-50 Treasury and SEC Request Comment on Proposed Regulation Regarding Broker/Dealer Anti-Money Laundering Customer Identification Requirements; Comment Period Expires September 6, 2002
• 02-47 Treasury Issues Final Suspicious Activity Reporting Rule for Broker/Dealers; Effective Date: Transactions After December 30, 2002
• 02-21 NASD Provides Guidance to Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law
• 01-67 Executive Order Targeting Terrorists

NYSE Regulation Information Memos

• NYSE 02-21 Approval of New Rule 445 – Anti-Money Laundering Compliance Program
• NYSE 06-4 Amendments to Rule 445 (“Anti-Money Laundering Compliance Program”) 

AML Forms

• Suspicious Activity Report (SAR S-F)
• Blocked Properties Reporting Form (OFAC)
• Voluntary Form for Reporting Blocked Transactions (OFAC)
• Voluntary Form for Reporting Rejected Transactions (OFAC)
• Report of Foreign Bank and Financial Accounts (FBAR)
• Currency Transaction Report (CTR)
• Report of International Transportation of Currency or Monetary Instruments (CMIR)
• Suspicious Activity Report for Insurance Companies (proposed) (SAR-IC) 

AML Education & Training

Live Events

• AML Classroom Learning
• Anti-Money Laundering Compliance Boot Camp

Online Workshops

• AML: Suspicious Activity Reporting 

• AML Reviews During Routine Exams

• AML Compliance

• Practices of Small Firms

Webcasts

• AML: Do You Know Your Customer? 
• AML:  Examples of Red Flags
• Anti-Money Laundering for Operations Staff
• Anti-Money Laundering—Institutional: Know Your Customer

E-Learning Courses

• AML – Retail: The Responsibility to Know Your Customer
• AML – Retail: Exploring New Risks
• AML – Retail: Recognizing and Escalating Suspicious Activity
• AML – Retail: The Responsibility to Know Your Customer
• AML—Retail: Recognizing Red Flags
• AML – Institutional: Identification and Reporting Issues
• AML – Institutional: Exploring New Risks
• AML – Institutional: Identifying and Managing Higher-Risk Clients 
• AML—Institutional: Recognizing Red Flags
• AML—Operations: Recognizing Red Flags

Phone-In Workshops

• AML Independent Testing

Additional AML Resources

• AML Service Providers 

AML Updates via email

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