Both the U.S. Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) continue to remind member firms that they take anti-money laundering (“AML”) violations very seriously. Both regulators cite AML as a focus in their examination priorities. In addition, both have recently announced regulatory actions against firms for alleged violations of AML requirements.
On January 5, 2016, FINRA released the eleventh edition of its “Regulatory and Examinations Priorities Letter.” The “areas of significance” designated by FINRA should be a primary focus for broker-dealer compliance personnel as part of their 2016 compliance program enhancements.
In 2014, the Financial Industry Regulatory Authority (FINRA) announced over 400 disciplinary actions against registered broker-dealers. Almost every action resulted in monetary fines. In several instances, firms were suspended or expelled as members. The fines for the year totaled nearly$132 million, which is significantly higher than the $69 million total in 2013.