The Regulatory Actions of Anti-Money laundering (AML) Spreads its Compliance Wings. Part I of III
AML compliance has traditionally been concentrated for the financial and banking industry. However regulators are now expected a widening the selection from financial institutions to Advisors, Brokers and Dealers in order to strengthen their controls against money laundering.
Investment Advisers, brokers and dealers must now also get ready to comply with the stricj global AML regulatory requirements so that the oversight authorities are able to carry out monitoring of customer and account checks and balances.
Financial institutions, banks, broker-dealers, and mutual funds have already established an existing AML framework to comply with a risk-based anti-money-laundering program with reporting of suspicious account activities.
In the US the SEC has started to levy multimillion-dollar fines against broker-dealers and cracked down on lapses in controls, inadequate customer monitoring and failure to report suspicious activity - penalties that show the seriousness with which the oversight authorities take AML lapses it oversees.
The new belief is that investment advisers are on the front lines of a multi-trillion dollar sector of the global financial system. Therefore to crack down on the cleaning, moving or stashing dirty money, investment advisers who often have an in depth knowledge of the reasons and size of the assets in questions must be vigilant and protect the integrity of the financial sector.
The Copenhagen Compliance® general GRC regulatory roadmap and framework consists of four pillars;
Ownership. Designate a compliance officer responsible for implementing and monitoring the program's operations and internal controls
Implementation. Establish document and implement written policies, procedures, and internal controls
Guidance. Provide ongoing training for employees on the GRC requirements relevant to their functions
Assessment. Provide independent compliance testing conducted by company personnel or a qualified outside party
In the following newsletters we will revisit and update the major requirements establishing an AML program, preparing for AML compliance (due diligence, examination, and enforcement remediation) and how to maintain an adequate customer identification program
For more details see; https://www.gpo.gov/fdsys/pkg/FR-2015-09-01/pdf/2015-21318.pdf
