Audit Solutions

AML Independent Testing:

Regulatory Compliance’s Anti-Money Laundering review is designed to satisfy the requirement for independent testing under FINRA Rule 3011(c) and related Bank Secrecy Act and Patriot Act regulations.

Through this review we attempt confirm the integrity and accuracy of the procedures for the reporting of large currency transactions; review forms filed with authorities, such as Forms 4790, CTR, SAR-SF, FBAR, etc. (to the extent they are not confidential); confirm the integrity and accuracy of the Company’s record keeping activities and adherence to in-house record retention policies; confirm compliance with the Company’s “know your customer” and CIP policies by conducting a review of a sampling of new account documentation, account reviews and transaction reviews; review the AML Supervisor’s records as they relate to specific monitoring of transactions or accounts, or follow-up on reported unusual activity; confirm adherence to the Company’s internal reporting procedures; confirm that all employees have been made aware of the Program, and have signed Attestations if required by the Company; ascertain that the Company is conducting an ongoing training program; and confirm that the Company’s Anti-Money Laundering Compliance Program incorporates changes required as a result of new legislation or regulation.

Mock FINRA Examination:

Regulatory Compliance’s Mock FINRA examination would include the following and would track closely with the FINRA’s checklist:

Examination of the Firm’s compliance system, including reviews of books and records such as ledgers, new account applications, customer complaint files, representative files, account files, advertising files, correspondence files, and continuing education records. In addition, we review the Written Supervisory Procedures manual, Anti-Money Laundering procedures, Training Plan and Business Continuity Plan. We attempt to understand and document the Firm’s supervisory compliance structure by interviewing Firm personnel and testing the supervisory system on a random basis to verify its adequacy and implementation.

Branch and Non-Branch Office Examinations:

Toward the goal of meeting the FINRA’s requirements of Rule 3010 for Broker Dealers to review offsite office locations, Regulatory Compliance’s offsite office examination includes the following:

Review of the Firm’s compliance with required branch or non-branch office procedures, including supervision and record keeping. We attempt to verify the adequacy and implementation of the office’s supervisory system by randomly reviewing books and records such as ledgers, new account applications, customer complaint files, representative files, account files, advertising files, correspondence files, and continuing education records. Our reviewer will make use of the Firm’s internal branch or non-branch office checklist, if desired.

Office Set-Up Visits:

These visits are designed to assist new Broker Dealers in preparing for their first FINRA visit (within 6 months of approval) and to ensure that they have the appropriate files in place to meet the Books and Records requirements.

The tone of the visit is set by the client. The visit can be done similar to a Mock FINRA Examination using a checklist and examining existing files or can be an interactive session where specific questions and issues are addressed and files are created or changed. A discussion on what to expect at the firm’s first FINRA examination and tips for preparing for the visit is also included.