Anti-Money Laundering

AML issues stemmed from the onboarding of hundreds of new customers domiciled in high-risk foregin jurisdictions

SEC and FINRA settlements offer the industry lessons learned as they cover a wide landscape of current compliance hot-buttons

At issue was language in the firm's WSPs concerning retail brokerage accounts

FINRA found that broker-dealer failed to conduct any independent testing of its AML program since at least 2018

Charges brought concerning customer ID program, failures to close or restrict thousands of high-risk accounts and SARs' filing failures

'You may see a delay of the registered investment adviser FinCEN rule, but I do think it will come out in some format'

SEC charges private fund adviser's AML due diligence practices were "materially inconsistent" with its representations to prospective and existing investors

As to whether future defendants should seek examiners’ materials to defend themselves, 'I think it would be a very effective argument'

Among other problems, LPL failed to properly verify new accounts; failed to timely close accounts that did not pass its CIP screening measures; and failed ...

Where red flags or 'high risk factors with respect to money laundering activities' were present, the firm didn't conduct the enhanced AML due diligence it ...