FINRA Member Broker Dealers are required to develop and implement a written anti-money laundering program reasonably designed to achieve and monitor its compliance with the requirements of the Bank Secrecy Act (31 U.S.C. 5311, et seq.), and the implementing regulations promulgated thereunder by the Department of the Treasury. 

A Broker Dealer anti-money laundering program must be approved, in writing, by a member of senior management and shall, at a minimum:

  • Establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required by Section 352 of the Patriot Act and under Section 5318(h) of title 31, United States Code and the implementing regulations thereunder;
  • Establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder;
  • Provide for annual (on a calendar-year basis) independent testing for compliance to be conducted by member personnel or by a qualified outside party, unless the member does not execute transactions for customers or otherwise hold customer accounts or act as an introducing broker with respect to customer accounts, in which case such “independent testing” is required every two years (on a calendar-year basis);
  • Designate and identify to FINRA an associated person or persons of the Firm responsible for implementing and monitoring the daily operations and internal controls of the program and provide prompt notification to FINRA regarding any change in such designation(s); and provide ongoing training for appropriate personnel.

NAMCOA can provide an AML report that is a test of a Broker Dealer’s Anti-Money Laundering Program.  The report covers a fiscal year and is a product of interviews/interactions with key personnel and review of available documentation. 


Our AML test process is approached from a risk perspective that includes discussions with the firm’s Principals, key officers, and review of relevant documents. Areas covered were as follows:

  • AML Program and Implementation
  • Client Risk, Business Risk and Geographic Risk
  • Suspicious Activity Monitoring
  • Reporting Requirements and Implementation

Our goal is to serve Broker Dealers and provide an AML Audit Report to demonstrate to FINRA that an AML Audit was completed in a timely manner.  Typically costs for an AML Audit for Broker Dealer ranges based on the number of Reps and offices.   

For small firms, less than 15 Reps and 3 offices, AML Audits start at just $1200.  

We know the importance of delivering the best customer experience and to exceed client expectations.  For more information, please contact us.