An Anti-Money Laundering (“AML”) compliance program combines every activity a firm performs to meet the constantly evolving AML compliance obligations: built-in internal operations, user-processing policies, accounts monitoring and detection, and reporting of money laundering incidents. DLA provides a wide variety of consultative services designed to assist an organization in all aspects of AML/Countering the Financing of Terrorism (“CFT”) compliance.
AML Independent Testing
FINRA Rule 3310(c) specifies that all broker-dealers registered with FINRA must periodically test the effectiveness of their AML compliance program using independent testing.
DLA partners with internal audit departments and regulatory compliance functions at its clients in developing comprehensive AML/CFT audit programs, including risk assessments and risk and control matrices. DLA also performs independent testing of existing AML programs on an outsourced or co-sourced basis and conducts audit validation to address any regulatory findings.
Design and Implementation of AML/CFT Risk Assessments
DLA assists clients with the design and implementation of AML/CFT risk assessments that are foundational to an effective AML compliance program. DLA also works with our clients to ensure their risk assessments are properly aligned with their AML/CFT compliance programs.
Properly designing, implementing, and enforcing risk-based policies and procedures to achieve compliance with the Bank Secrecy Act (“BSA”) and the regulations under FINRA Rule 3310(b) are fundamental qualities to a firm’s AML compliance program.
FINRA Rule 3310(e) also specifies that all broker-dealers registered with FINRA must provide training on an on-going basis for registered persons and all employees within certain functions.
DLA works with its clients in creating customized and pertinent AML/CFT training which is a pillar to a successful AML/CFT compliance program. DLA assists organizations with the development, implementation and delivery of training that is customized to reflect a company’s primary business activities, customer profile, current AML/CFT and sanctions knowledge base, and internal procedures.
The aim of an AML compliance program is to detect, respond to, and eliminate inherent and residual money laundering, terrorist financing, and fraud-related risks. DLA partners with its clients in a cost-effective manner to ensure that they can keep pace with the challenges of AML compliance.