AML Compliance Program

Read the Free Lesson โ†’ free ยท no signup wall

What this video covers

  • How the BSA, FinCEN, and FINRA's AML program requirement fit together in the statutory hierarchy, and which of the three enforces a missed suspicious activity filing
  • The five required pillars of the AML program requirement, including which pillar was added most recently by FinCEN's Customer Due Diligence (CDD) rule
  • Why beneficial ownership identification belongs to pillar 5, not the Customer Identification Program (CIP), and what the 25% equity threshold triggers
  • How to determine whether a firm requires annual or biennial independent testing based on whether it executes customer transactions, holds customer accounts, or acts as introducing broker
  • What structural independence means for the tester, and why the tester cannot report to the AMLCO
  • The 30-day deadline to update FINRA on AMLCO contact changes versus the 17-business-day annual verification after calendar year end
  • Why Priya must always identify at least one control person for a legal-entity customer even when no single owner meets the 25% threshold

Read the full lesson, free

This video's complete written lesson is free to read in the CertFuel app, no signup wall. The complete Series 24 course also includes adaptive practice questions and spaced-repetition flashcards, free through the end of 2026.

Read the Free Lesson โ†’ free ยท no signup wall