Anti-money laundering is a continuously evolving issue that places additional due diligence and reporting responsibilities on firms, supervisors, and registered representatives.
Section 352 of the USA PATRIOT ACT amended the BSA to require financial institutions to establish an AML program, report suspicious activity, verify the identity of customers and apply due diligence in all matters especially to accounts involving foreign persons.
Broker-dealers can meet this requirement by maintaining an AML compliance program that complies with SRO rule requirements. NASD Rule 3011 and NYSE Rule 445 require their member organizations to establish risk-based AML compliance programs.
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