AML Compliance Program
Chapters in this video
- 0:00 BSA, FinCEN, and FINRA: the statutory flow to Priya's desk
- 1:21 Layered enforcement trap: who knocks when Riley misses a SAR
- 2:21 The five pillars of the AML program requirement
- 3:44 Annual versus biennial independent testing frequency
- 5:54 AMLCO deadlines: 30 days for changes, 17 business days for verification
- 7:27 Beneficial ownership at 25% and the always-one control person rule
- 8:34 Rapid-fire exam recap
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.