Broker-dealers have the regulatory obligation to conduct an independent Anti-Money Laundering (“AML”) audit annually. Oyster will compare your firm’s written policies and procedures, actual practices and books and records to the requirements and regulations of the USA PATRIOT Act, the Bank Secrecy Act, and FINRA Rule 3310 and industry best practices, by testing records using risk-based and random sampling methods. We will prepare a request list of records required to complete the review and provide the list prior to an on-site visit. Oyster will prepare a draft discussion report of efficient and practical ways to close gaps and achieve best practices, prior to issuing a final report.
Included in an Oyster AML Audit are:
- AML Program Approval and Oversight
- Bank Secrecy Act (“BSA”) Compliance
- Customer Identification Program (“CIP”)
- Financial Crimes Enforcement Network (“FinCEN”) Information Requests/Sharing
- Review of Accounts, including High Risk Accounts
- Office of Foreign Assets Control (“OFAC”)
- Suspicious Activity Reporting
- Training and Education
The Oyster Difference
Oyster’s consultants, many of whom are former Chief Compliance Officers, compliance officers, and AML officers, have themselves been subject to AML audits and know what it’s like to sit in your seat. We will work with your team to make sure our assessment is fair and accurate. Oyster has worked with many different types of broker-dealer clients, small to large, with a variety of different clearing firms and business models.