The US Financial Industry Regulatory Authority (FINRA) has published a list of AML regulatory obligations and related considerations. FINRA requires that members develop and execute an adequate AML compliance program to fulfill the obligations listed by the Bank Secrecy Act.
In its report, FINRA has identified some of the most important risks for financial crimes. These include inadequate AML transaction monitoring, inadequate suspicious activity reports, insufficient AML framework for cash management accounts, improper assignment of AML responsibilities, etc. Moreover, FINRA has identified Microcap and Special Purpose Acquisition Companies as some areas with emerging financial crime risks. FINRA has also noted that the owners of certain restricted foreign national and foreign entity nominee accounts are perhaps being directed by others, which adds to the risks.
To fight these emerging risks, it is important to implement effective AML/CFT practices. FINRA has recommended a Customer Identification Program that undertakes a risk-based use of documentary and non-documentary methods to verify customer identities. It also recommends the use of extra precautions when opening accounts. The authority also advises the use of AML compliance tests, risk assessments and AML training programs.
Source: FINRA