FINRA Rule 3310 requires that each broker-dealer undertake annually an independent AML test for compliance. Such testing is to be conducted by member personnel or by a qualified outside party. Members that do not execute transactions for customers or otherwise hold customer accounts or act as an introducing broker with respect to customer accounts (e.g., engages solely in proprietary trading or conducts business only with other broker-dealers), are required to undertake “independent testing” every two years (on a calendar-year basis).
BD Financial Services senior partner has in excess of twenty-five years financial institution senior management compliance experience and has provided consultative services to professionals in the legal and financial profession related to interpretation of the SEC Act of ‘33 and ‘34, the Maloney Act, the Investment Advisors Act of 1940, the Bank Secrecy Act, GAAP, SEC requirements that exceed GAAP, corporate governance and general business matters. Our manager was involved in the implementation of the Bank Secrecy Act requirements at NASD member firms and has been engaged in anti-money laundering procedures and testing since inception of the requirement. In 2014, he met with and reviewed his qualifications and test format with staff of the SEC in Ft. Worth, Texas. There were no concerns or objections to his qualifications or the test format.