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Industry Risks and Threats – Resources for Member Firms

FINRA provides these resources to assist member firms with managing and addressing potential risks and threats that may pose harm to their business, compliance programs and investors, including:

  • highlights of recent risks observed in FINRA’s regulatory programs;
  • observations from recent targeted exams (sweeps) on emerging industry issues and related regulatory obligations; and
  • FINRA resources, that touch on topics of particularly significant ongoing and emerging threats to firms and investors—such as cybersecurity, fraud, anti-money laundering (AML) and sanctions.

Member firms may consider using these resources to help evaluate and enhance their supervisory and compliance programs. These resources do not create new legal or regulatory requirements or new interpretations of existing requirements, nor do they relieve firms of any existing obligations under federal securities laws and regulations.

Updated: This page was last reviewed and updated, on August 12, 2025, and does not reflect any regulatory changes since that date. FINRA periodically reviews and updates materials so they can be an evolving resource for firms. Firms should stay apprised of new or amended laws, rules, and regulations, and update their written supervisory procedures and compliance programs on an ongoing basis.

2025 FINRA Annual Regulatory Oversight Report — Financial Crime Prevention — NEW FOR 2025

The 2025 FINRA Annual Regulatory Oversight Report includes several updates to its Financial Crime Prevention section, which is focused on helping firms address financial crime and other industry risks and emerging threats:

Member firms should also review the Firm Operations section, which includes a new section on Third-Party Risk Landscape that contains shared observations and effective practices relating to third-party vendor risks (including recent increases in cyberattacks and outages).

Sweep Updates

FINRA conducts targeted exams, or sweeps, to review firms' conduct relating to certain emerging industry issues and help focus our regulatory responses.

To support our ongoing goals of transparency with the industry and help firms continually improve their compliance programs, FINRA publishes sweep letters and provides updates to share initial themes from our reviews. Most recently, we provided updates on four of our most significant sweeps, including:

FINRA Provides Update on Sweep: Crypto Asset Communications

This update summarizes initial themes from this targeted exam and poses questions for firms to consider if they use retail communications concerning Crypto Assets, including:

  • accuracy of statements or claims; and
  • fair and balanced presentation.

Member firms may consider the information in this update in developing new, or modifying existing, policies and procedures that are reasonably designed to achieve compliance with relevant regulatory obligations based on the member firm’s size, business model, or practices.

The update also provides links to additional resources.

FINRA Provides Update on Sweep: Special Purpose Acquisition Companies (SPACs)

The update highlights a number of initial themes from our reviews of firms’ offering of, and services provided to, SPACs and their affiliates (e.g., sponsors, principal stockholders, board members, and related parties) and includes questions for firms to consider as they evaluate whether their supervisory systems are reasonably designed to address risks of their SPAC-related activities, including:

  • reasonable investigation of the issuers and the securities they recommend, including SPACs;
  • underwriting compensation and disclosures;
  • identifying, addressing and disclosing potential or actual conflicts of interest when underwriting or recommending transactions in SPACs; and
  • firms’ supervisory systems, procedures, processes, and controls for underwriting and recommending transactions in SPACs.

FINRA Provides Update on Sweep: Social Media Influencers, Customer Acquisition and Related Information Protection

This update focuses on firms’ practices and supervisory systems regarding their social media influencer and referral programs, such as maintaining:

  • written supervisory procedures (WSP) that differentiate between social media influencer and referral programs and address firms’ obligations under Regulation S-P;
  • written policies regarding social media influencer and referral program participants’ compensation and conduct; and
  • written policies regarding sharing customer information with third parties (including permitting customers to opt out of information sharing).

FINRA Provides Update on Sweep: Option Account Opening, Supervision and Related Areas

This update includes questions for consideration for members based on FINRA’s observations to this point in its review to help firms evaluate whether their supervisory systems adequately address risks related to supervising the approval of options accounts and monitoring the trading activity in options accounts, including questions addressing:

  • processes for collecting and reviewing customer information;
  • disclosures about options trading; and
  • supervision of approved options accounts.

Compliance Resources on Key Risks and Threats

The sections below provide select resources on ongoing and emerging risks in areas that may present significant threats to member firms and investors.

Alerts and Advisories

FINRA issues alerts and advisories, as well as alerts issued by other government and non-governmental organizations, that concern potential cybersecurity attacks relevant to member firms. Additional alerts are available under the Guidance tab of FINRA’s Cybersecurity Key Topic Page.

Regulatory Notices

FINRA provides guidance for member firms on relevant regulatory obligations, effective practices and other resources to help firms evaluate and enhance their compliance programs. Additional Notices are available on FINRA’s Notices page.

  • Regulatory Notice 24-09 (FINRA Reminds Members of Regulatory Obligations When Using Generative Artificial Intelligence and Large Language Models). This Notice reminds member firms that are incorporating the use of generative artificial intelligence (Gen AI) or similar tools into their businesses about potential implications for their regulatory obligations and opportunities for engagement with FINRA.
  • Regulatory Notice 23-06 (FINRA Shares Effective Practices to Address Risks of Fraudulent Transfers of Accounts Through ACATS). This Notice provides an overview of some indicators of ACATS fraud and the practices some firms apply to address it.
  • Regulatory Notice 22-29 (FINRA Alerts Firms to Increased Ransomware Risks). This Notice provides questions firms can use to evaluate their cybersecurity programs in light of the increased ransomware threat, lists possible additional firm controls and provides relevant resources.
  • Regulatory Notice 22-25 (Heightened Threat of Fraud: FINRA Alerts Firms to Recent Trend in Small Capitalization (“Small Cap”) IPOs). This Notice alerts firms to a recently observed, emerging threat to customers and member firms, where FINRA, NASDAQ and NYSE have observed initial public offerings (IPOs) for certain small capitalization (small-cap) issuers listed on U.S. stock exchanges that may be the subject of pump-and-dump-like schemes.
  • Regulatory Notice 22-21 (FINRA Alerts Firms to Recent Trend in Fraudulent Transfers of Accounts Through ACATS). This Notice provides an overview of how bad actors effect fraudulent transfers of customer accounts using ACATS (referred to as ACATS fraud), lists several existing regulatory obligations that may apply in connection with ACATS fraud, and provides contact information for reporting the fraud.
  • Regulatory Notice 22-18 (FINRA Reminds Firms of Their Obligation to Supervise for Digital Signature Forgery and Falsification). This Notice addresses the risks presented by signature forgeries and falsifications by identifying the relevant regulatory obligations and describing the scenarios member firms reported to FINRA where representatives forged or falsified customer signatures, as well as the methods firms used to identify the forgeries or falsifications.
  • Regulatory Notice 22-06 (U.S. Imposes Sanctions on Russian Entities and Individuals). This Notice provides member firms with information regarding the sanctions the U.S. government imposed in February 2022 in response to Russia’s actions in Ukraine.
  • Regulatory Notice 21-36 (FINRA Encourages Firms to Consider How to Incorporate the Government-Wide Anti-Money Laundering and Countering the Financing of Terrorism Priorities Into Their AML Programs). This Notice informs member firms of the Financial Crimes Enforcement Network’s (FinCEN) government-wide priorities for anti-money laundering and countering the financing of terrorism policy, which was mandated by the Anti-Money Laundering Act of 2020 (AML Act).
  • Regulatory Notice 21-29 (FINRA Reminds Firms of their Supervisory Obligations Related to Outsourcing to Third-Party Vendors). This Notice reminds firms about applicable regulatory obligations for vendor management; summarizes recent trends in examination findings, observations and disciplinary actions; and provides questions member firms may consider when evaluating their systems, procedures and controls relating to Vendor management.
  • Regulatory Notice 21-18 (FINRA Shares Practices Firms Use to Protect Customers From Online Account Takeover Attempts). This Notice outlines the increase in ATO incidents observed in 2021; reiterates firms’ regulatory obligations to protect customer information; and discusses common challenges firms identified in safeguarding customer accounts against ATO attacks, as well as practices they find effective in mitigating risks from ATOs—including recent innovations—which firms may consider for their cybersecurity programs.
  • Regulatory Notice 21-14 (FINRA Alerts Firms to Recent Increase in ACH “Instant Funds” Abuse). This Notice warns member firms of a sharp increase (as of March 2021) in new customers opening online brokerage accounts and engaging in Automated Clearing House (ACH) “instant funds” abuse to effect securities trading, and urges firms to evaluate and, as appropriate, mitigate the potential financial risk they face in light of the increase in “instant funds” abuse.
  • Regulatory Notice 21-03 (FINRA Urges Firms to Review Their Policies and Procedures Relating to Red Flags of Potential Securities Fraud Involving Low-Priced Securities). This Notice provides information that may help FINRA member firms that engage in low-priced securities business assess and, as appropriate, strengthen their controls to identify and mitigate their risk, and the risk to their customers, including specified adults and seniors, of becoming involved in activities related to fraud involving low-priced securities.
  • Regulatory Notice 20-32 (FINRA Reminds Firms to Be Aware of Fraudulent Options Trading in Connection With Potential Account Takeovers and New Account Fraud). This Notice provides member firms and associated persons with information regarding options transactions in connection with these account takeover and new account fraud schemes to help identify, prevent and respond to such activity.
  • Regulatory Notice 20-30 (Fraudsters Using Registered Representatives Names to Establish Imposter Websites). This Notice describes certain common characteristics of imposter websites and actions firms and registered representatives can take to monitor for and address these sites. 
  • Regulatory Notice 20-13 (FINRA Reminds Firms to Beware of Fraud During the Coronavirus (COVID-19) Pandemic). This Notice outlines four common scams to which firms and their customers were exposed during the COVID-19 pandemic: (1) fraudulent account openings and money transfers; (2) firm imposter scams; (3) IT Help Desk scams; and (4) business email compromise schemes—and describes measures that firms and associated persons may take to mitigate related risks. 
  • Regulatory Notice 19-18 (FINRA Provides Guidance to Firms Regarding Suspicious Activity Monitoring and Reporting Obligations). This Notice provides guidance to member firms regarding suspicious activity monitoring and reporting obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program).

Other Compliance Resources

FINRA has developed a number of compliance resources, such as compliance tools, checklists, templates and directories, that help member firms with fulfilling their regulatory obligations, implementing written supervisory procedures (WSPs) and tailoring their policies and procedures to reflect their size, business model and regulatory needs. Additional compliance tools are available on FINRA’s Compliance Tools page.

  • Core Cybersecurity Threats and Effective Controls for Small Firms 
    This tool helps small firms enhance their customer information protection, and cybersecurity WSPs and related controls by (1) highlighting common categories of cybersecurity threats; (2) providing a summary of core controls; and (3) listing relevant terms and additional resources.   
  • Cybersecurity Checklist
    This checklist helps small firms establish and evaluate their data protection policies and controls.
  • Firm Checklist for Compromised Accounts
    This checklist includes practices and steps firms may consider if they learn that an unauthorized person may have gained access to customers’ accounts.
  • Insider Threats – Effective Controls and Practices
    This publication summarizes effective controls and practices we have observed firms employ to manage insider threat risks, as well as relevant questions for consideration that firms may use to evaluate their current insider threat programs.
  • Anti-Money Laundering (AML) Template for Small Firms
    This template provides text examples, instructions, relevant rules, websites and other resources that help small firms develop an AML compliance program plan.
  • Frequently Asked Questions (FAQ) regarding Anti Money Laundering (AML)
    This page provides answers to FAQs regarding FINRA Rule 3310 and firms’ AML requirements, including the required elements of firms’ AML compliance programs; whether firms’ AML compliance personnel have to be registered principals; how the Customer Identification Program (CIP) defines “account” and “customer”; and whether there are any exceptions from the Suspicious Activity Reporting (SAR) reporting requirement.

Podcasts

FINRA staff gather to share insights from our regulatory programs, including recent emerging risks facing member forms on our podcast, FINRA Unscripted. Additional podcasts are available on our FINRA Unscripted page.

  • Vendor Vigilance: Navigating Third-Party Risk (May 06, 2025). Third-party risk is the most clicked-on topic in FINRA's 2025 Regulatory Oversight Report. But what is third-party risk and why are people so interested in it? What can FINRA member firms do to mitigate that risk? And how can FINRA help? These questions will be answered on the latest episode of FINRA Unscripted, featuring a returning guest, FINRA's Executive Vice President of Member Supervision Greg Ruppert.
  • Protecting Investors: FINRA Securities Helpline for Seniors' 10th Anniversary (Apr 01, 2025). This month, we are marking the 10th anniversary of the FINRA Securities Helpline for Seniors—an important milestone for a critical service that FINRA provides to protect vulnerable investors and assist harmed investors. On this FINRA Unscripted podcast episode, we will be speaking with leaders from FINRA's Vulnerable Adults and Seniors Team—Elizabeth Yoka, the manager of VAST Intake, and Michael Paskin, the manager of the VAST Investigations, to discuss the Helpline and its 10 years of protecting investors.
  • Protecting Yourself from Financial Fraud: Navigating an Evolving Landscape (Mar 04, 2025). On this episode, a member of the FINRA Investor Education Foundation team joins us to talk about how we can all become more informed and vigilant in today's complex financial world.
  • Using Data to Stay Ahead of Risk: Introducing FINRA's StratIntel Team (Feb 11, 2025). As the financial industry continues to evolve, it's important to stay ahead of emerging risks and trends. On this episode of FINRA Unscripted, we sit down with the leaders of FINRA's new Strategic Intelligence and Analytics team to discuss how they are working to identify and analyze these industry developments.
  • Investing Wisely in 2025: Avoiding Scams and Achieving Your Financial Goals (Jan 07, 2025). FINRA's Head of Investor Education shares insights on leveraging market trends and tools to achieve your money goals in 2025 while avoiding scams.
  • Special Investigations Unit: Combating Money Laundering and Fraud in the Securities Industry (November 12, 2024). In the securities world today, there is little daylight between money laundering and fraud. On this episode, we learn how FINRA’s Special Investigations Unit works to detect and investigate cases of illicit finance and market abuse, as well as how they proactively identify and mitigate threats.
  • The Victim Experience: When Romance Leads to a Crypto Scam (October 1, 2024). Falling victim to a scam carries more than just a financial impact. It can be an isolating experience and exact a mental and emotional toll. On this episode, we hear about the experience of two real life victims and their efforts to recover from their loss with the help of the Cybercrime Support Network.
  • Disrupting the Cycle of Financial Fraud Through Collaboration and Innovation (September 17, 2024). Last week, FINRA CEO Robert Cook spoke at a conference hosted by the FINRA Foundation to underscore the importance of working together to disrupt the cycle of fraud. He highlighted specific areas for further coordination and announced that FINRA will reach out operators of existing regulatory databases to explore ways to create a one-stop shop resource for investor research. On this episode, we tune in to his remarks.
  • Financial Intelligence Unit: Connecting FINRA Members with Actionable Information (July 9, 2024). FINRA's Financial Intelligence Unit acts as a nerve center for information on emerging threats impacting the financial industry with the aim of providing actionable intelligence to firms, other regulators and law-enforcement to keep investors safe. On this episode, we learn how the group has grown in recent years and hear how they are evolving the way they share information.
  • FINRA’s High-Risk Representative Program: Keeping an Eye on Individuals Posing a Heightened Risk of Misconduct (May 28, 2024). Protecting investors from harm is a top FINRA priority. And when it comes to specific individuals who may pose a risk, FINRA's High-Risk Representative Program is on the case, identifying and monitoring individuals who pose an elevated risk of misconduct to protect investors and maintain the integrity of the market.
  • Insider Trading Detection: FINRA’s Vital Role in Ensuring Market Integrity (May 14, 2024). Every day, FINRA's Insider Trading Detection Program uses sophisticated technology and analytics to monitor 100% of trading in stocks, options and bonds for potentially suspicious activity around material news events, resulting in hundreds of referrals to the SEC and law enforcement every year. On this episode, we hear how the team connects trading data, information from public sources and from companies and FINRA firms to pull together actionable intelligence.
  • Fighting Financial Exploitation: FINRA’s Vulnerable Adults and Seniors Team (April 30, 2024). On this episode, we hear from members of both the Vulnerable Adults and Seniors (VAST) Intake and Investigations teams to hear how the groups work with individual investors, firms, states and other regulators to prevent and detect financial exploitation of senior and other vulnerable investors.
  • A Cybersecurity Update with FINRA's Complex Investigations and Intelligence Team (April 2, 2024). These days, it's not a matter of if, but when, when it comes to cybersecurity incidents, which is why it's essential for all firms to ensure they're prepared for the inevitable. On this episode, we're catching up with two members of FINRA's Complex Investigations and Intelligence Team for an update on the cyber threat landscape and what firms should be thinking about and doing in response to the latest trends.
  • An Evolving Landscape: Generative AI and Large Language Models in the Financial Industry (March 5, 2024). While Generative AI and large language models (LLMs) present numerous opportunities to create business efficiencies and offer many potential benefits to firms, regulators and investors, they also introduce unique risks. On this episode, we hear from three experts at FINRA who are closely looking at these technologies and following developments in this space.
  • Compliance and Communication: An Update on FINRA’s Crypto Asset Targeted Exam (January 23, 2024). This episode delves into the results of FINRA's targeted review of certain member firms and their communications to retail investors regarding crypto products and services.
  • Introducing FINRA's Complex Investigations and Intelligence team and Cyber and Analytics Unit (August 2022). This episode introduces FINRA’s recently established Complex Investigations and Intelligence team and Cyber and Analytics Unit, and discusses how these new groups will help FINRA better deliver on its mission of investor protection and market integrity.
  • Overlapping Risks, Part 2: Anti-Money Laundering and Elder Exploitation (November 10, 2020). This episode discusses how firms’ AML risks may overlap with their efforts to protect senior investors from exploitation and fraud.
  • Overlapping Risks, Part 1: Anti-Money Laundering and Cybersecurity (October 27, 2020). This episode covers the intersection of firms’ AML and cybersecurity risks, and how firms can best manage these risks.
  • Beyond Hollywood, Part II: AML Priorities and Best Practices (May 14, 2019). This episode continues the discussion from the previous “Beyond Hollywood” episode, covering current priorities and best practices when it comes to anti-money laundering regulation.
  • Beyond Hollywood, Part I: Money Laundering in the Security Industry (April 30, 2019). This episode explains what money laundering is, how it looks different in the securities industry, how that makes regulation different for the securities industry, and what FINRA’s Anti-Money Laundering Investigative Unit does.