On October 26, 2001, the United States enacted the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “MLA Act”) as part of the USA PATRIOT Act (the “PATRIOT Act”) in order to combat money laundering. Money laundering is the process by which criminals try to conceal the true origin and ownership of the proceeds of their criminal activities by passing them through the legitimate banking and financial services system. If undertaken successfully, it allows criminals to maintain control over those proceeds and ultimately to provide a legitimate cover for the source of their income. Money laundering provides the fuel for drug dealers, terrorists, arms dealers, and other criminals to operate and expand their criminal enterprises.

In order to prevent this money laundering activity, the FINRA implemented Rule 3011 requiring that broke-dealers set up and maintain anti-money laundering programs which include written procedures, client identification programs, a review of suspicious activity, employee AML training and an independent testing of the AML program, at least annually.

Mallon & Johnson conducts this independent testing of a firm’s AML program. Generally our testing will encompass the following:

AML Officer's role;
Customer identification procedures;
Customer Verification procedures;
Cashiering procedures;
Detection and Reporting of suspicious activities; and
Training of Employees concerning AML.
Generally, Mallon & Johnson charges a flat fee for this service, determined by the complexity of the AML program.

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