FINRA Provides Template AML Policies and Procedures
FINRA has issued template Anti-Money Laundering policies and procedures that include sample language (in Word format for editing) as well as annotations to applicable law. FINRA describes the template as assistance for small firms and stresses that each firm should conduct its own “risk-based” assessment. The template includes a wide range of applicable provisions: AML officer responsibilities, FinCEN reporting, OFAC checks, customer identification programs, foreign correspondent accounts, suspicious activity monitoring, recordkeeping, training, and testing.
OUR TAKE: Although described as a “small firm” template, the template policies and procedures (49 pages long) appear to address the full spectrum of AML issues. We would recommend using the template as a starting point and amending as appropriate. The template would also serve the needs of investment advisers.