Wall Street has developed a sophisticated third party audit program that at a minimum:

(1) Review and test firm AML policies and procedures to ensure they are up-to-date and being followed;

(2) Establish and implement policies, procedures and internal controls reasonable designed to achieve compliance with the BSA and other regulatory authorities;

(3) Designate and individual responsible for implementing and monitoring the day-to-day operations and internal controls of the AML program. A Compliance Officer who has the authority, knowledge and training to carry out the duties and responsibilities of his or her position;

(4) Provide ongoing AML annual training to appropriate firm personnel; and

(5) Provide for independent annual testing by a qualified third party.

In today’s complex and at times confusing regulatory environment, “knowing your customers” as defined under FINRA Rule 2310 is not enough. To meet these rigorous requirements and regulatory scrutiny, WSCS has developed programs that will at minimum:

(1) Ensure all firm accounts are properly indentified, verified and documented as required under CIP;

(2) Run all accounts through OFAC to ensure no accounts are Foreign Shell Banks, terrorists, Specially Designated Nationals, Blocked Persons or from embargoed countries;

(3) Conduct a review of trading and flows of money from and between accounts clarifying origins and destinations, frequency of deposits and withdrawals, wire transfers, and patterns in the movement and transferring of assets;

(4) Detect red flags/ suspicious activity and ensure proper reporting;

(5) Ensure Correspondent Accounts notifications are sent ensuring specified banks do not obtain access to covered US financial institutions;

(6) Test for proper management and board reporting;

(7) Ensure the firm’s internal training programs are adequate and cover all appropriate individuals;

(8) Ensure proper firm record keeping.

As part of the Wall Stree Audit Package our clients will receive a comprehensive report describing the components of the audit devidiencies noted and corrective action recommendations to become compliant. In addition our clients receive copies of all signed disclosures and attestations, a copy of the program and all areas tested and copies of all test documents and backup for record keeping purposes.

AML compliance is not a “one-size-fits-all” requirement. Each firm’s size, location, business activities, account types and the types of transactions its customers engage must be factored and tailored into a unique individualized program specific to the firm. Wall Street Consulting Services (“WSCS”) can meet all your AML compliance needs. Whether you are looking to create a whole new AML program, to update an existing program or just use WSCS for your annual AML audit, we are the Expert’s for you.

money laundering red flags   OFAC risk factors