NASD Rule 3011 requires that every member, except those who only do proprietary trading or engage in transactions with other broker/dealers, to have an annual independent review of their AML program. This testing is to be completed on a calendar year basis and may be completed by someone at the member who is “independent” or by a qualified outside party.

Many firms don’t believe that they are subject to this requirement as they don’t handle cash.  To date the NASD has not made any exceptions for this requirement, except as outlined above.  You can try to meet this requirement in-house but many firms find they need to seek outside assistance.

Here in the sales department of Regulatory Compliance we find many firms panicking right before the NASD is coming in, as they have not taken care of their independent AML review.  Regulatory Compliance is here to help you take care of your AML testing requirements.    For those that need help we have experienced AML testing professionals that can assist.  Please contact either Rich Horgan or Karen Hagan for more information or to arrange for your annual AML testing today!