1. Anti-Money Laundering Program
a. An AML program must be in writing and include, at a minimum;
i. Policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and its implementing rules;
ii. Policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under 31 U.S.C. 5318(g) and the implementing regulations thereunder;
iii. The designation of an AML compliance officer (AML Officer), including notification to the SROs; Ongoing AML employee training; and
iv. An independent test of the firm s AML program, annually for most firms.
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