Anti-Money Laundering

Independent Anti-Money Laundering (AML) Program Testing

Gaining an unbiased assessment of how your firm’s anti-money laundering compliance program meets AML mandates—and of where you stand in regard to money laundering risk—requires regular, comprehensive AML program testing. The certified experts at Rubicon Consulting Group (RCG) provide independent testing of the anti-money laundering compliance program for FINRA member broker/dealers as well as SEC and state Registered Investment Advisors (RIAs).

For valid independent AML program testing, auditors for your firm must first and foremost meet two basic requirements:

  • Anti-money laundering compliance program auditors must be knowledgeable of all AML standards and the various applications of AML rules as they apply to broker-dealers and investment advisors.
    • RCG AML specialists are well-versed in the relevant AML mandates not only of the Bank Secrecy Act (BSA) and the USA Patriot Act of 2001, but also of such governmental administrators and regulators as the Securities and Exchange Commission (SEC), the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), and the Financial Industry Regulatory Authority (FINRA).
  • Anti-money laundering compliance program auditors must be independent of the functions being tested (i.e. an auditor cannot be your designated AML compliance person, a member of your AML compliance team, or any individual who reports to either).
    • RCG’s testing professionals offer the third-party money laundering compliance testing your firm requires. Our experts include FINRA Certified Regulatory Compliance Professionals (CRCP) with extensive anti-money laundering experience.

Trusted AML Compliance Services

RCG tailors your AML test to stress those requirements most relevant to the business operations of your firm, with an eye to those AML compliance programs and business transactions that present the highest levels of risk.  RCG’s AML testing includes a review and analysis of business operations, an analysis of AML supervision and management, and an evaluation of your firm’s books and records.

RCG’s anti-money laundering compliance services include:

  • Assessment of changing regulatory rules and Procedures
  • Ensuring BSA and FINRA Rule 3310 compliance
  • Confirming all money laundering reporting requirements are met
  • Ensuring the satisfaction of record keeping requirements—Know Your Customer (KYC) and Customer Identification Program (CIP)
  • CIP risk assessment, source of funding, entity formation
  • Designated Compliance Person
  • Suspicious Activity Reports (SAR)
  • Money transfer and wires
  • U.S. Treasury’s Office of Foreign Assets Control (OFAC) and Specially Designated Nationals And Blocked Persons List (SDN)
  • Beneficial Ownership and Customer Due Diligence (CDD)
  • Correspondence accounts
  • Source documentation

Once testing is complete, RCG’s report will provide the following:

  • Synopsis of findings and recommendations
  • Details of the manner and method of your firm’s internal AML compliance testing
  • Report on firm compliance with your AML supervisory system and AML WSP
  • Summary of gaps discovered
  • Identification of the changes your firm has made or will need to make to enhance the effectiveness of your AML compliance program

Rubicon Consulting Group, LLC stands ready to address any deficiencies discovered through anti-money laundering compliance testing.  Please contact us if you have further questions regarding anti-money laundering requirements or would like more information about our AML testing services.