FINRA Updates AML Rules to Conform to Upcoming Customer Due Diligence Requirements

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The Financial Industry Regulatory Authority published amendments to FINRA Rule 3310, the anti-money laundering compliance program rule.  The FINRA amendments seek to harmonize Rule 3310 with the Customer Due Diligence Requirements for Financial Institutions rule issued by the U.S. Financial Crimes Enforcement Network on May 11, 2016.  Amended Rule 3310 requires firms to conduct ongoing customer due diligence, establish procedures to understand the nature and purpose of customer relationships for the purpose of developing a customer risk profile, conduct ongoing monitoring to identify and report suspicious transactions and, on a risk basis, maintain and update customer information, including information regarding the beneficial ownership of legal entity customers.  Amended Rule 3310 becomes effective on May 11, 2018, which coincides with the compliance date for FinCEN’s CDD Rule.

View full text of Regulatory Notice 18-19.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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