Banyan failed to conduct any independent testing of its AML program in any calendar year from at least 2018 through the present, and its written AML program did not include any procedures providing for independent testing for compliance from February 2022 through the present, in violation of FINRA Rules 3310(c) and 2010. For these violations, Banyan consents to a censure, a fine of $15,000, and an undertaking requiring the firm, within 90 days, to conduct an independent test and revise its written AML program to require independent AML testing each calendar year.