How is the anti-money laundering program audited or tested?
If your firm is a clearing firm, or a firm that specializes in online brokerage activity, we will probably be asking you some additional or different questions. Clearing brokers. We understand that, traditionally, it is the introducing firm that is responsible for knowing the customer, and has the relationship with the customer. But, the introducing firm does not have all the transaction data that the clearing firm has. We will look to see if the exception reports made available to introducing brokers assist the introducing broker in monitoring for money laundering activity, and what steps the clearing firm is taking to review the information it has obtained. The introducing/clearing relationship should not create a gap in the industry’s monitoring for money laundering purposes. Online Brokers. The use of the Internet, and electronic signature technology, also raises new questions for money laundering compliance. The online brokerage firm administers accounts in a setting that promotes
