There have been two important changes in the world of Anti-Money Laundering
(“AML”) compliance. First, on January 1, 2010, in connection with FINRA’s rule
consolidation, FINRA Rule 3310 went into effect, which replaces NASD Rule 3011.
Second, FINRA released its long-awaited revised AML Small Firm Template, which will
provide guidance to firms and help them to further enhance their existing AML policies
and procedures. Both of these updates include a number of corresponding changes which
firms should be aware of for their AML compliance programs.
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