Firm Policy - Anti-Money Laundering (AML) Program - Compliance and Supervisory Procedures

Sep 1, 2026

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Updated small-firm AML template text sets out a risk-based Anti-Money Laundering (AML) program aligned to U.S. regulatory expectations, emphasizing written risk assessment, tailored policies, procedures, and internal controls. It clarifies that the template does not create obligations, does not guarantee compliance, and no small-broker-dealer exemption applies. It explains how to address inapplicable rules when circumstances change, including CIP triggers and additional AML duties such as suspicious activity monitoring and reporting. Guidance also directs firms to FINRA, FinCEN, SEC AML resources and BSA e-filing for SAR submissions.

LanguageEnglish

CategoryForms

FormatDOCX

Pages58

Reading Time20 min

AccessFree to download

Anti-Money Laundering (AML) Program

Compliance and Supervisory Procedures

Risk-Based AML Program Design

Internal Controls When Circumstances Change

Sample Policy Language and Guidance Resources

Updated Small Firm Template [Firm Name] Anti-Money Laundering (AML) Program: Compliance and Supervisory Procedures UPDATED AS OF MONTH DAY, YEAR This template is provided to assist small firms in fulfilling their responsibilities to establish an Anti-Money Laundering (AML) Program as required by the Bank Secrecy Act (BSA) and its implementing regulations and FINRA Rule 3310 (AML Compliance Program). Nothing in this template creates any new requirements for AML programs. Furthermore, following this template does not guarantee compliance with AML Program requirements or provide a safe harbor from regulatory responsibility. There is no exemption from the AML rules for small broker-dealers. Your firm’s AML program should be “risk-based.” That means that the program’s AML policies, procedures and internal controls should be designed to address the risk of money laundering specific to your firm. Your firm can identify that risk by looking at the type of customers it serves, where its customers are located, and the types of services it offers. It is a good practice to develop a written analysis of your firm’s money laundering and terrorist financing risk and how your firm’s AML procedures manage that risk. This “risk-assessment” will help to ensure that the AML program is the right one for your firm and is a useful tool for demonstrating to your firm’s examiner that the firm used a reasonable approach for designing its AML program. In addition, where certain AML rules may be inapplicable due to the limited nature of your firm’s business, FINRA expects your firm to have internal controls in place to identify when circumstances change in such a way as to trigger previously inapplicable AML requirements and to amend your AML policies and procedures to accurately reflect all AML requirements that are applicable to your business. For example, a firm with no customer accounts within the definition of the Customer Identification Program (CIP) rule would not be expected to have a CIP. However, the firm must have procedures in place to identify when the firm’s business activities have shifted in such a way as to require compliance with the CIP rule. In addition, notwithstanding the fact that the firm does not have accounts for CIP purposes, the firm is expected to identify and develop procedures for any additional AML requirements that do apply (e.g., suspicious activity monitoring and reporting). The language in this template is provided only as a helpful starting point to walk you through developing your firm’s program. If any of the language does not adequately address your firm’s business situation in any respect, you will need to prepare your own language. You are responsible for ensuring that the program fits your firm’s risk level and that you implement the program. TEXT EXAMPLES are provided to give you sample language that you can modify, as necessary, to fit your firm’s needs in creating your firm’s program. Material in italics provides instructions and citations to the relevant rules, and other resources that you can use to develop your firm’s program. The HYPERLINK "http://www.finra.org/RulesRegulation/IssueCenter/Anti-MoneyLaundering/index.htm" FINRA AML web page includes important information and links to other websites with useful information. You should also consult the websites maintained by the HYPERLINK "http://www.fincen.gov" Financial Crimes Enforcement Network (FinCEN) and the HYPERLINK "http://www.sec.gov" Securities and Exchange Commission (SEC), including the HYPERLINK "http://www.sec.gov/about/offices/ocie/amlsourcetool.htm" SEC’s AML Source Tool, for additional information and guidance. For historical guidance and background, you may wish to consult NASD Notices to Members (NTM) HYPERLINK "http://www.finra.org/RulesRegulation/NoticestoMembers/2002NoticestoMembers/p003703" 02-21, HYPERLINK "http://www.finra.org/industry/notices/02-47" 02-47, HYPERLINK "http://www.finra.org/industry/notices/0

FAQs

What is the purpose of the small-firm AML program template?

It assists small firms in developing an AML program to meet responsibilities under the Bank Secrecy Act (BSA) and related regulations, including FINRA AML expectations. It does not create new requirements or guarantee compliance.

How should a firm structure its AML program?

The program should be risk-based, with policies, procedures, and internal controls designed to address money-laundering risks specific to the firm’s customers, geography, and services. A written money laundering and terrorist financing risk assessment is recommended to support regulatory examinations.

What if certain AML rules appear inapplicable to the firm?

FINRA expects internal controls to identify when business changes trigger previously inapplicable AML requirements. Firms must then amend AML policies and procedures and develop procedures for any additional applicable requirements, including suspicious activity monitoring and reporting.

Where can firms find additional AML guidance and how do they submit SARs?

The FINRA AML web page and resources from FinCEN and the SEC provide guidance. For BSA filings such as Suspicious Activity Reports (SARs), firms must use FinCEN’s BSA E-Filing System.

Sep 1, 2026

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