Independent Reviews are a key part of any organization's compliance program, providing essential oversight and helping to ensure that compliance policies and procedures are being followed. They provide an objective, unbiased assessment of an organization's compliance with laws and regulations and can help identify areas where improvements are needed.
Bates provides independent Compliance and AML reviews for Registered Investment Adviser, Broker-Dealer, and hybrid firms, as well as Private Fund and Hedge Fund clients. We also serve established and start-up companies in the areas of banking, fintech (financial technology), virtual asset and cryptocurrency firms, traditional Money Services Businesses (MSBs), and Non-Banking Financial Institutions (NBFIs).
BSA/AML Independent Reviews - as required by FinCen under the Bank Secrecy Act to ensure that your organization's Anti-Money Laundering program is effective and in compliance.
Consumer Compliance Independent Reviews - to assess the quality of your compliance risk management systems, including its internal controls and policies related to its consumer products and services, including Regulation E.
New York Department of Financial Services (NYDFS) Rule 504 Independent Reviews - conducted as a “gap analysis” or as full annual NY 504 Review or Model & System Validation Testing (required by applicable licensees).
Broker Dealer and Registered Investment Advisor Reviews - per FINRA and SEC Rules
Independent Anti-Money Laundering Reviews
FINRA Rule 3310 requires that Broker-Dealers (“BDs”) conduct independent Anti-Money Laundering (“AML”) program testing on a calendar year basis or more frequently if circumstances warrant. The independent testing must be conducted by a person with working knowledge of applicable requirements under the Bank Secrecy Act and its implementing regulations. Our consultants are CAMS, CRCM, and CFRM certified, and some are former regulators who have specific insight into the review process and BSA/AML requirements.
Bates' independent AML review is designed to meet the requirements of FINRA Rule 3310, the Bank Secrecy Act, and the USA PATRIOT Act. Our assessment of the adequacy and effectiveness of the AML Program will include a review of the following:
- AML Program Governance
- Key personnel experience
- A sampling of Know Your Client (“KYC”) information
- A review of the firm Customer Identification Program (“CIP”)
- OFAC/SDN sanction list screening
- Transaction monitoring and surveillance
- Suspicious Activity Reporting (“SAR”)
- Employee Training
Upon completion of the review, a written report will be provided that details Bates’ observations and recommendations for improvement, where applicable.