ITA Brokers - AML Testing Services


ITA Compliance provides independent testing and compliance consulting services to broker-dealers throughout the United States. Our clients' businesses vary and include the independent retail model, investment banking firms, institutional trading, and proprietary trading firms. Our clients also vary by the number of registered representatives, clearing arrangements, types of clients, number of branch and OSJ locations, affiliations with other financial services businesses, and regulatory history.

  • Anti-Money Laundering (AML) Testing
  • Supervisory Controls Testing
  • OSJ inspections
  • Mock Examinations and Preparation for Regulatory Visits
  • Custom Examinations and Consulting Projects

Anti-Money Laundering (AML) Testing

ITA Compliance's consultants have conducted AML examinations for over 100 broker-dealers. Different businesses require different AML approaches. We have examined firms who serve retail customers, conduct investment banking activities, and engage in institutional trading.

Our testing is designed to evaluate a 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); OFAC and other government lists; SARs and required filings; red flag monitoring; employee training; and other areas as required by internal policies and procedures.

Supervisory Controls Testing

ITA Compliance conducts supervisory controls testing for broker-dealers on a rolling 12-month basis. In consultation with the firm, ITA 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 use the results of this evaluation to suggest the areas to be tested. Once we agree on a scope of testing, ITA examiners interview the firm's associates and review related books and records to determine whether the firm is following industry rules and firm policies 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.

Office of Supervisory Jurisdiction (OSJ) Inspections

ITA Compliance conducts inspections of broker-dealer OSJ locations 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. ITA works with the firm to identify firm-specific requirements and design an appropriate testing plan. Firms often find it helpful to have us test for compliance with rules and requirements governing pre-hire documentation, outside business activities, advertising and social media, e-mail review, business continuity and information security, among other areas.

Other Broker-Dealer Projects

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

For more information about our services including pricing, please complete the online form located here or contact us directly at 617-854-7500.