Broker-Dealers

ITA Compliance, LLC’s consultants have conducted AML examinations for over 100 broker-dealers. Many of these firms engage in trading for retail customers. However, as broker-dealer business models vary, ITA Compliance, LLC has also customized its testing program over many years to uniquely approach the needs of non-retail broker-dealers, such as investment banking firms, placement agents, and institutional trading (DVP/RVP) brokers.

Our testing is designed to evaluate your firm’s compliance with the USA PATRIOT Act/Bank Secrecy Act, FINRA Rule 3310, and OFAC regulations. Specifically, we review a variety of areas, including the firm’s written AML policies and procedures, customer identification program (CIP), FinCEN Customer Due Diligence (CDD) requirements, OFAC and other government lists, SARs and required filings, activity monitoring, employee training, and other areas as required by internal policies and procedures.

ITA Compliance, LLC conducts supervisory controls testing for broker-dealers on a rolling 12-month basis. In consultation with the firm, ITA Compliance, LLC will evaluate and select areas for review based on a risk assessment. We evaluate the firm’s regulatory history, supervisory structure, approved products, revenue sources, types of customers, regulatory rule changes, and material changes to the firm and its operations. We also consult current examination priorities and recent enforcement actions. The results of this evaluation will be used to suggest the areas to be tested.

Once the scope of the review has been determined, ITA Compliance, LLC will interview the firm’s key personnel and review related books and records. Testing will be designed to determine whether the firm has adopted reasonable supervisory control procedures, and whether there are any gaps between written procedures and supervisory processes. Our testing observations and recommendations are memorialized in a report designed to support senior management in attesting to the annual certification required by FINRA Rule 3130.

ITA Compliance, LLC regularly conducts home office OSJ inspections for broker-dealers in order to satisfy FINRA Rule 3110(c). FINRA has outlined five specific areas to be reviewed during this testing: safeguarding of customer funds and securities, supervision of supervisory personnel, transmittal of funds, changes of customer account information, and maintenance of books and records. Regarding books and records, ITA Compliance, LLC will collaborate with the firm to identify specific requirements and design an appropriate testing scope.

ITA Compliance, LLC assists broker-dealers with other regulatory compliance projects such as mock FINRA/SEC exams, evaluation and development of branch inspection programs, and regulatory enforcement actions requiring the hiring of independent consultants.