Anti-Money Laundering Program Review
Under the USA PATRIOT Act and FINRA Rule 3310, many broker-dealers are required to annually review their anti-money laundering procedures to be certain they are meeting regulatory requirements. Our staff includes a Certified Anti-Money Laundering Specialist and Certified Financial Crime Specialist, as well as other compliance professionals who have worked with banks and broker dealers to develop and run successful anti-money laundering programs.. We can help by reviewing the adequacy of your firm’s AML compliance policies and procedures, and the effectiveness of their implementation. The review includes:
- Analyzing and testing your supervisory policies and procedures
- Reviewing a test sample of client files with an emphasis on foreign clients
- Checking out your internal surveillance practices
- Assessing your AML training program
- Evaluating your AML documentation
We will then provide you with a written report highlighting deficiencies and with recommendations on how to improve your program.
SEC Readiness Assessment
We can help you gauge your readiness for an SEC examination. We will work with you to determine your greatest areas of risk, as well as those areas that the SEC has identified as hot topics / focus areas. We will request initial information be provided electronically as it is available, based on the request list most currently used by the SEC Examination staff. Then our consultants will perform a review and analysis of the information provided by your Firm to select samples, request additional information, and identify individuals to interview while on-site. This initial preparation will allow us to make more efficient use of the time spent in your office reviewing your books and records. We will make suggestions to you and your staff during the office visit, provide you with an overview in the form of an exit interview, and email a written report (if requested) shortly after the visit. The format of the report will be agreed upon with your Firm.
The on-site visit will be 1-2 days. In addition, we will provide 10 hours of remote consulting in the form of emails and telephone calls for 30 days following completion of the Assessment. The consulting provided will relate to any deficient areas covered within the SEC Readiness Assessment.
We can perform a detailed review and analysis of your Firm’s current compliance policies and procedures including your Firm’s Code of Ethics and Business Continuity Plan and all parts of Form ADV for compliance with applicable regulatory requirements, consistency among internal documents, and suggested industry best practices. We will make written recommendations on strengthening those areas needing improvement. The review will be completed remotely and include 5 hours of consulting as it relates to the suggestions made during the Gap Analysis.
Our firm can perform a comprehensive assessments of your fiduciary process. One of our managing directors, Jaqi Hummel, is an independent Accredited Investment Fiduciary Analyst (AIFA® ), and works with the Centre for Fiduciary Excellence to conduct independent assessments of investment advisers’ ability to meet a fiduciary standard. The assessment submits an investment adviser’s process, practices and procedures to assess how well it conforms to the Global Fiduciary Standard of Excellence as measures of risk and trustworthiness of investment fiduciaries. The process uses the ISO 19011 audit standard, an internationally recognized standard for testing process management systems. The assessment is subject to review by the CEFEX Registration Committee comprised of independent fiduciary experts.The assessment typically includes document review, client file sampling, on-site visits and interviews with senior representatives at the firm.
We are available to assist your compliance efforts in other ways as well. No time to perform your annual assessment of the compliance program? Our consultants can perform that review cost-effectively and efficiently, with the added benefit of providing an independent viewpoint. Want to know whether your compliance manual covers all the latest rules, regulations and best practices? We can perform a gap analysis and let you know where you might want to improve. Considering purchasing an investment adviser but don’t know whether there are any regulatory skeletons in the closet? Our experienced consultants know what to ask and where to look to find potential issues.