FINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering Program required by the USA PATRIOT Act of 2001 and NASD Rule 3011. The template provides language concerning, among other things, the final customer identification rule. The template also contains instructions, relevant rules and Web Sites, and other resources that are useful for developing an AML plan for a small firm.
8/16/07
Please note: The Financial Crimes Enforcement Network has issued final rules to implement requirements set forth in Sections 311 and 312 of the USA PATRIOT Act, which have not yet been incorporated into the template. These rules include 31 CFR 103.176, 31 CFR 103.188, 31 CFR 103.192, and 31 CFR 103.193. This template does not reflect these recent changes.
FINRA is in the process of updating the template and will notify firms when it becomes available. In the interim, firms should carefully review these rules and update their AML programs, as appropriate. See generally
FinCEN's Web site; see also
FinCEN's Federal Register Web page announcing relevant proposed and approved regulations.
