Independent Anti-Money Laundering Reviews

Engaging Cobia Compliance to conduct your AML audit will give you confidence that your firm is in compliance with FINRA’s annual anti-money laundering testing requirements as set forth in FINRA Rule 3310. Cobia guarantees that at least one Cobia associate on site at every audit will hold the CAMS (Certified Anti-Money Laundering Specialist) credential.

AML Audit Process

Upon engaging Cobia Compliance, Cobia will work with your firm to establish the scope and timing of your independent AML testing. A pre-audit request list will be furnished so that documents can be ready prior to our arrival for the on-site portion of your audit. Once the on-site audit is concluded, a post-audit interview will be conducted. Finally, both draft and final reports will be provided.

Scope of the AML Review

  • Written AML policies and procedures
  • Customer Identification procedures/KYC/customer due diligence
  • Suspicious Activity Reporting (SARs)
  • OFAC reporting and tracking
  • Employee AML training
  • Clearing firm arrangements
  • Transaction testing
  • Exception reporting

The list of review items is not intended to be exhaustive but rather to give examples of the areas and content to be reviewed during the course of the audit.

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