Anti-Money Laundering (AML)

Firms must comply with the Bank Secrecy Act and its implementing regulations ("AML rules"). The purpose of the AML rules is to help detect and report suspicious activity including the predicate offenses to money laundering and terrorist financing, such as securities fraud and market manipulation.

FINRA reviews a firm’s compliance with AML rules under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program. The basic tenets of an AML compliance program under FINRA 3310 include the following.

  1. The program has to be approved in writing by a senior manager.
  2. It must be reasonably designed to ensure the firm detects and reports suspicious activity.
  3. It must be reasonably designed to achieve compliance with the AML Rules, including, among others, having a risk-based customer identification program (CIP) that enables the firm to form a reasonable belief that it knows the true identity of its customers.
  4. It must be independently tested to ensure proper implementation of the program.
  5. Each FINRA member firm must submit contact information for its AML Compliance Officer through the FINRA Contact System (FCS).
  6. Ongoing training must be provided to appropriate personnel.
  7. The program must include appropriate risk-based procedures for conducting ongoing customer due diligence, including (i) understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and, (ii) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, including information regarding the beneficial owners of legal entity customers.

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Anti-Money Laundering Template for Small Firms

FINRA provides an Anti-Money Laundering Template to assist Small Firms in establishing the AML compliance program required by the Bank Secrecy Act, its implementing regulations, and FINRA Rule 3310. 

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Frequently Asked Questions

Find answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.

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AML Reports and Systems

E-Learning

FINRA's Anti-Money Laundering (AML) e-learning courses cover concepts and strategies for detecting and preventing money-laundering activity. Each course presents unique scenarios that illustrate typical money-laundering situations.

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Contact OGC

FINRA's Office of General Counsel (OGC) staff provides broker-dealers, attorneys, registered representatives, investors and other interested parties with interpretative guidance relating to FINRA’s rules. Please see Interpreting FINRA Rules for more information.

OGC staff contacts:

Victoria Crane
Tom Kimbrell
FINRA, OGC
1700 K Street, NW
Washington, DC 20006
(202) 728-8000

  • 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
    02/10/2021
  • Regulatory Notice 20-13
    FINRA Reminds Firms to Beware of Fraud During the Coronavirus (COVID-19) Pandemic
    05/05/2020
  • Regulatory Notice 19-18
    FINRA Provides Guidance to Firms Regarding Suspicious Activity Monitoring and Reporting Obligations
    05/06/2019
  • Regulatory Notice 18-36
    FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
    10/19/2018
  • Regulatory Notice 18-19
    FINRA Amends Rule 3310 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions
    05/03/2018
  • Regulatory Notice 17-40
    FINRA Provides Guidance to Firms Regarding Anti-Money Laundering Program Requirements Under FINRA Rule 3310 Following Adoption of FinCEN's Final Rule to Enhance Customer Due Diligence Requirements for Financial Institutions Effective Date: *
    11/21/2017
  • Regulatory Notice 12-08
    SEC Requests Broker-Dealers Make SARs and SAR Information Available to FINRA
    02/10/2012
  • Regulatory Notice 09-60
    SEC Approval and Effective Dates for New Consolidated FINRA Rules
    10/15/2009
  • Notice to Members 07-17
    NASD and NYSE Joint Release Regarding Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
    04/18/2007
  • Notice to Members 06-41
    Special Measures against Specified Banks Pursuant to Section 311 of the USA PATRIOT Act
    08/14/2006
  • Notice to Members 06-07
    SEC Approves Amendments to Anti-Money Laundering Compliance Program Rule and Adoption of Interpretive Material
    02/10/2006
  • Notice to Members 03-34
    Treasury and SEC Issue Final Rule Regarding Customer Identification Programs for Broker/Dealers
    06/20/2003
  • Notice to Members 02-80
    Development Regarding Treasury Information Requests Under Section 314 of the PATRIOT Act
    12/02/2002
  • Notice to Members 02-78
    NASD Adopts Amendments to Rule 3011 to Require Members to Provide to NASD Contact Information for an Anti-Money Laundering Compliance Person(s)
    10/31/2002
  • Notice to Members 02-50
    Treasury and SEC Request Comment on Proposed Regulation Regarding Broker/Dealer Anti-Money Laundering Customer Identification Requirements
    08/13/2002
  • Notice to Members 02-47
    Treasury Issues Final Suspicious Activity Reporting Rule for Broker/Dealers
    08/12/2002
  • Notice to Members 02-21
    NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law
    04/10/2002
  • Notice to Members 01-67
    Executive Order Targeting Terrorists
    10/10/2001
  • FAQ
    Frequently Asked Questions (FAQ) regarding Anti-Money Laundering (AML)
    Answers to frequently asked questions regarding FINRA Rule 3310 and AML program requirements.
  • Guidance
    Anti-Money Laundering, Fraud and Sanctions
    The Anti-Money Laundering, Fraud and Sanctions topic of the 2024 FINRA Annual Regulatory Oversight Report (the Report) informs member firms’ compliance programs by providing annual insights from FINRA’s ongoing regulatory operations, including (1) regulatory obligations and related considerations, (2) findings and effective practices, and (3) additional resources.
    January 09, 2024
  • Media Center
    AML Update: The Latest Trends and Effective Practices
    Money laundering looks different in the securities industry and that poses its own challenges. Add to that a landscape of constantly evolving threats and it is a lot to keep up with. On this episode, we hear about emerging threats and how firms can ensure their AML program remains strong and effective.
    May 31, 2022
  • Guidance
    Sanctions Alert: Russia-Related Sanctions

    The Special Investigations Unit (SIU) within FINRA’s National Cause and Financial Crimes Detection (NCFC) program is bringing to your attention some additional Russia-related sanctions developments. Please note that these are in addition to those detailed in FINRA Regulatory Notice 22-06. 

    February 28, 2022
  • Podcast
    Overlapping Risks, Part 2: Anti-Money Laundering and Elder Exploitation
    A broker-deal firm’s anti-money laundering efforts may overlap with any number of other regulatory concerns. On this episode, the second in a two-part series, we’re looking at how AML may overlap with a firm’s efforts to protect senior investors from exploitation and fraud.
    November 10, 2020
  • Podcast
    Overlapping Risks, Part 1: Anti-Money Laundering and Cybersecurity
    Firm regulatory risks and priorities don't exist in a vacuum. And that is perhaps nowhere clearer than when it comes to a firm's anti-money laundering responsibilities. A firm's AML risks can overlap with any number of other priorities. On this episode, the first of a two-part series, we look at the overlapping risks of AML and cybersecurity.
    October 27, 2020
  • Podcast
    Encore | Beyond Hollywood: Money Laundering in the Securities Industry
    This episode originally aired in April 2019. The only thing many people know about money laundering is what they’ve learned from Hollywood. So if you want to really understand what money laundering is, and more specifically, the efforts brokerage firms must take to prevent and detect it, tune in. On this episode we talk to two of FINRA’s Anti-Money Laundering experts.
    August 04, 2020
  • Virtual Conference Panel
    Financial Crimes, Trends and Responses – In the Midst of the Pandemic
    COVID-19 has altered the world as we know it. While some have responded to it as an incident or singular event, in the world of countering criminal threats we are seeing the need to treat it as a sustained campaign. This panel will discuss the multitude of threats across the financial crimes’ spectrum perpetrated by an aggressive yet flexible adversary.
    June 09, 2020
  • Podcast
    Introducing Greg Ruppert and the National Cause and Financial Crimes Detection Programs
    Between the level of interconnectedness on the web and the sheer about of data available, we’re living in an era ripe for the perpetration of financial fraud. That makes it more important than ever for FINRA to have a holistic view of emerging trends and risks—and the ability to coordinate closely with other regulators and law enforcement. FINRA’s new National Cause and Financial Crimes Detection Programs (NCFC) will be the nerve center to do just that.
    May 26, 2020
  • FAQ
    Frequently Asked Questions Related to Regulatory Relief Due to the Coronavirus Pandemic

    Due to the coronavirus pandemic (COVID-19), FINRA is providing temporary relief for member firms from rules and requirements in the Frequently Asked Questions below. The relief provided does not extend beyond the identified rules and requirements. FINRA will continue to monitor the situation to determine whether additional guidance and relief may be appropriate. As coronavirus-related risks decrease, member firms should expect to return to meeting any regulatory obligations for which relief has been provided.

    March 24, 2020
  • Podcast
    Beyond Hollywood, Part II: AML Priorities and Best Practices
    The world of money laundering is a fast-paced and ever evolving, which can make it difficult for a financial firm to develop and maintain a strong anti-money laundering program. On this episode, two FINRA anti-money laundering experts discuss current priorities and best practices when it comes to AML regulation.
    May 14, 2019
  • Compliance Tools
    Anti-Money Laundering (AML) Template for Small Firms
    FINRA provides a template for small firms (Word format 164 KB) to assist them in fulfilling their responsibilities to establish the Anti-Money Laundering Program. The template provides language concerning, among other things, the final customer identification rule.
    July 18, 2018
  • Guidance
    Comparison of the AML Customer Identification Rule and the SEC’s Books & Records Customer Account Records Rule
    Two important regulatory developments relate to obtaining customer information: the Anti-Money Laundering Customer Identification Rule and the SEC's Books and Records Customer Account Records Rule. These rules require that important customer identification be obtained. However, these rules have critical differences including their purposes, their definitions, and their timing requirements. We created this document to assist our member firms. It contains brief summaries of the rules' relevant provisions.
    September 01, 2003
  • Guidance
    What to Expect: Anti-Money Laundering Reviews During Routine Examinations
    This webcast focuses on what firms should expect from the Anti-Money Laundering reviews conducted as part of FINRA's routine examinations. We will review how FINRA examiners will check to make sure you have appropriate AML procedures in place, and you will learn what we expect of you and what you should expect from us during the AML part of an exam.