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Financial Services Law Insights and Observations

FINRA advises firms to incorporate FinCEN’s AML/CFT priorities

Financial Crimes Of Interest to Non-US Persons FINRA Anti-Money Laundering Combating the Financing of Terrorism Agency Rule-Making & Guidance FinCEN Risk Management Bank Secrecy Act

Financial Crimes

On October 8, the Financial Industry Regulatory Authority (FINRA) encouraged member firms to consider ways to incorporate recently issued anti-money laundering and countering the financing of terrorism priorities (AML/CFT Priorities) into their risk-based compliance programs. As previously covered by InfoBytes, the Financial Crimes Enforcement Network’s (FinCEN) AML/CFT Priorities—issued pursuant to the Anti-Money Laundering Act of 2020—highlighted key threat trends and provided informational resources to help covered institutions manage their risks and meet their obligations under laws and regulations designed to combat money laundering and counter terrorist financing.

FINRA reminded member firms that FINRA Rule 3310 requires the development and implementation of a written AML program to achieve compliance with the Bank Secrecy Act (BSA). While FinCEN’s issuance of the AML/CFT Priorities “does not trigger an immediate change in the BSA requirements or supervisory expectations for member firms,” FINRA advised member firms to evaluate how they plan to incorporate these priorities into their risk-based AML programs. Among other things, FINRA advised member firms to: (i) review red flags based on potential risks presented by their business activities, size, geographic location, and types of accounts and transactions; and (ii) consider potential technical changes, including those used to monitor and investigate suspicious activity.

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