Alerts

Amendments to NYSE Rule 445 and NASD Rule 3011 - Anti-Money Laundering Program Rules Under Section 352 of the Patriot Act

February 2, 2006
SRZ Client Memorandum

Section 352 of the Patriot Act required that each financial institution, as defined under the Bank Secrecy Act ("BSA"), establish an AML program by April 24, 2002 that included, at a minimum: (1) the development of internal policies, procedures, and controls; (2) the designation of a compliance officer; (3) an ongoing employee training program; and (4) an independent audit function to test programs. Pursuant to an Interim Final Rule issued by Treasury on April 23, 2002, a broker-dealer will be deemed to satisfy the AML requirements of the BSA if it complies with any regulations of its federal functional regulator with respect to AML programs, maintains an AML program that complies with the rules issued by its self-regulatory organization ("SRO"), and the rules of the SRO have been approved, if required, by its supervising regulator.