AML Compliance Services for Broker-Dealers, Bank-Dealers, and RIAs

What Is AML Compliance?

Anti-money laundering (AML) compliance is the program of policies, procedures, internal controls, and testing that financial firms must maintain under the Bank Secrecy Act (BSA) to detect and report suspected money laundering, terrorist financing, and other illicit finance activity. For broker-dealers, the core requirements are set by FINRA Rule 3310, MSRB Rule G-41, Treasury's Financial Crimes Enforcement Network ("FinCEN"), and the USA PATRIOT Act. A compliant program must, at minimum, include written policies and procedures, a designated AML compliance officer (AMLCO), ongoing employee training, independent testing, and risk-based customer due diligence including beneficial ownership identification.

Who Needs an AML Program

Every FINRA member broker-dealer and bank-dealer must maintain a written AML program under FINRA Rule 3310 and MSRB Rule G-41, subject to periodic independent testing (1 - 2 years depending on firm's activities and risk). FinCEN's Investment Adviser AML Rule was finalized in 2024, and on December 31, 2025, FinCEN delayed the effective date to January 1, 2028. Covered RIAs and exempt reporting advisers may consider using the extended runway to scope an AML program now rather than scramble in 2027.

AML Program Design and Build-Out

We draft and amend the written AML program tailored to your business lines, products, customer base, and geographies, which includes AMLCO governance, escalation protocols, and board or senior management reporting; build or refresh the BSA/AML risk assessment with documented methodology and rationale; and integrate AML policies with WSPs, Reg BI, Reg S-P, and supervisory controls so the program functions as one supervisory system.

Annual Independent AML Testing

ARS conducts the AML Reviews in accordance with the Bank Secrecy Act, FINRA Rule 3310(c) and MSRB Rule G-41, as applicable to independently test on an annual or, where eligible, biennial basis. Our risk-based testing covers CIP, CDD, beneficial ownership, transaction monitoring, OFAC, SAR/CTR filings, recordkeeping, and training. Each engagement concludes with a written report containing findings, root-cause analysis, and recommendations. We also perform independent tests for non-FINRA firms, including RIAs preparing for 2028 and bank-dealers.

AML Training

We deliver annual firmwide AML training and onboarding training for new hires which covers an overview of money laundering, the FinCEN Five Pillars (including beneficial owners), the Patriot Act - Customer Identification Program, due diligence, FinCEN reviews, red flags, and Suspicious Activity Reports (SARS). Delivery is on-site or remote with attendance tracking and exam-ready documentation.

Transaction Monitoring and Surveillance

ARS' AML surveillance program includes reviewing deal files for proper due diligence, CIP, FinCEN, OFAC, etc., wire transfers, training, registration, and procedures.

Regulatory Exam and Enforcement Support

ARS handles day-to-day interface with FINRA, the SEC, FinCEN, and state regulators on AML matters. We prepare firms for FINRA AML cycle exams and SEC examinations of dual registrants.

Our Approach

First, we assess your current program, risk profile, and prior exam history to identify gaps and over-engineered controls. Second, we implement, build, or rebuild documents, controls, and surveillance calibrated to actual risk, not a generic template. Third, we offer training to the AMLCO, supervisors, and registered persons on what the program requires and why. Fourth, we provide ongoing support by monitoring rule changes, running testing, filing reports, and serving as a continuous extension of your compliance team.

Why ARS for AML

Our team has over 100 years of combined compliance experience reviewing AML programs at national, regional, and boutique firms. We take a pro-business approach, calibrating controls to the actual risk in your business rather than the worst case across the industry. We speak the language of the SEC, FINRA, MSRB, FinCEN, and state regulators, and we continuously monitor rule changes (IA AML Rule timeline) and sanctions updates.

Frequently Asked Questions

How often does a broker-dealer need an independent AML test?

Under FINRA Rule 3310(c), a broker-dealer must perform independent testing of its AML program on an annual basis. Firms that do not execute transactions with customers or otherwise hold customer accounts, and that do not act as introducing brokers, may qualify to test every two years. The testing must be performed by a qualified person who is not the AMLCO and who does not report to the AMLCO.

Can the AML independent test be performed in-house?

Yes, if the firm has personnel who are independent of the AML function, possess sufficient subject-matter expertise, and do not report to the AMLCO. Most small and mid-size broker-dealers find it more efficient, and more defensible during a FINRA exam, to engage an outside specialist.

What are the core elements of a written AML program?

Under FINRA Rule 3310, a written AML program must include: (1) policies, procedures, and internal controls reasonably designed to achieve compliance with the BSA; (2) independent testing; (3) a designated AML compliance officer; (4) ongoing employee training; and (5) appropriate risk-based procedures for conducting ongoing customer due diligence, including beneficial ownership identification and ongoing monitoring.

When does the FinCEN Investment Adviser AML Rule take effect?

On December 31, 2025, FinCEN issued a final rule extending the effective date of the Investment Adviser AML Rule from January 1, 2026, to January 1, 2028. FinCEN has also indicated it may further tailor the rule's scope before that date. Covered RIAs and ERAs should treat 2026 and 2027 as preparation years.

What does an outsourced AMLCO arrangement look like?

For firms that prefer not to staff a full-time AMLCO, outsourced personnel can serve as the named or de facto AMLCO under a written engagement, run day-to-day AML operations, file SARs and CTRs, conduct training, and interface with regulators. The firm retains ultimate responsibility, and the relationship should be properly documented to satisfy FINRA expectations on outsourced supervisory functions.

How long does it take to build an AML program from scratch?

For a new broker-dealer going through the FINRA New Member Application (NMA) process, ARS typically delivers a complete AML program, including the written program, risk assessment, training plan, and testing schedule, in four to eight weeks, calibrated to the firm's planned business activities.

Ready to Strengthen Your AML Program?

Schedule a free consultation with our AML experts.