FINRA Rule 3011 requires that member firms adopt and implement anti-money laundering programs; Sections 352 and 326 of the The USA PATRIOT Act require firms to have written AML and customer identification programs. Testing is required annually for almost all firms on a calendar basis. Of note: SEC and FinCEN have signed an information sharing agreement. SEC can report results from routine exams to FinCEN, which will follow up by investigating perceived non-compliance with Federal AML requirements.
