Treliant Takeaway…Observations from Anti-Money Laundering Compliance Examinations of Broker-Dealers 

  • Source:

Treliant Takeaway:

As a follow up to the Risk Alert released in 2021, the Security Exchange Commission’s (SEC) Division of Examinations released a new Risk Alert highlighting recent examination observations identified in key Anti-Money Laundering (AML) compliance program requirements for broker-dealers. Treliant offers comprehensive services that address these concerns including independent AML and sanctions program reviews, training, tailored risk assessments, customer identification program (CIP) and customer due diligence (CDD)/beneficial ownership support that range from developing and enhancing processes, policies and procedures, as well as providing ongoing compliance expertise support.


The Risk Alert underscores the significance of key AML compliance program requirements, including:

  • independent testing of firms’ AML programs;
  • comprehensive training of personnel; and
  • diligent identification and verification of customers and their beneficial owners.

These observations highlight the need for broker-dealers to devote sufficient resources to AML and OFAC/sanctions compliance, particularly if resources are shared, and to design, implement, and update policies, procedures, and internal controls consistently.

The SEC also emphasizes the effectiveness of policies and the sufficiency of supervisory, compliance, and other risk management systems. These factors should be evaluated in the context of each firm’s specific risk profile and other relevant circumstances. The alert further serves as a guide for firms to consider in identifying potential risks and issues, assessing existing risk management systems, and making necessary enhancements to address or strengthen such systems.

While the alert is not an official SEC rule or regulation, it serves as a valuable guide for firms to identify and address potential risks in their AML compliance programs. More information can be found in the Division of Examinations’ website.

This Treliant Takeaway was authored by Richard Lee.

Ready to Talk?

We work with you to understand your needs, so we can tailor our approach to your engagement. Learn more when you connect with our team.