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Financial Services Law Insights and Observations

FINRA revises anti-money laundering template for small firms

Agency Rule-Making & Guidance FINRA FinCEN Anti-Money Laundering Customer Due Diligence Department of Treasury Bank Secrecy Act Financial Crimes CDD Rule

Agency Rule-Making & Guidance

On April 4, the Financial Industry Regulatory Authority (FINRA) released a revised template to assist FINRA-registered small firms in developing and implementing risk-based anti-money laundering (AML) programs as required by the Bank Secrecy Act and FINRA Rule 3310. Changes to the template reflect FinCEN’s final rule concerning customer due diligence requirements for covered financial institutions (CDD rule), which goes into effect May 11. (See previous InfoBytes coverage on the CDD rule here.) The CDD rule requires covered financial institutions, including FINRA-registered firms, to identify the beneficial owners of legal entity customers who open new accounts.

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