FINRA Releases AML/CFT Priorities


Tom Grygiel

Publish Date


Compliance Alert

  • Compliance
  • AML and Financial Crime

On October 8, 2021, FINRA issued Regulatory Notice 21-36 urging firms to consider how to incorporate the government-wide Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Priorities into their AML programs.


The Anti-Money Laundering Act of 2020 became law on January 1, 2021 updating the Bank Secrecy Act (BSA). The law requires the Financial Crimes Enforcement Network (FinCEN) to issue AML/CFT Priorities at least once every four years. In response, FinCEN issued the following AML/CFT Priorities, its first release, on June 30, 2021:

  • Corruption
  • Cybercrime, including relevant cybersecurity and virtual currency considerations
  • Foreign and domestic terrorist financing
  • Fraud
  • Transnational criminal organization activity
  • Drug trafficking organization activity
  • Human trafficking and human smuggling
  • Proliferation financing

What this means for broker-dealers

FINRA Rule 3310 requires firms to develop AML programs that comply with BSA requirements. Although covered financial institutions do not have to act until FinCEN issues its final AML/CFT Regulations, FINRA encourages firms to take a risk-based approach by initiating their response to the published priorities now (and, in the future, as soon as priorities are published). As part of this risk-based approach, firms should consider updating their procedures for acquiring, creating, and later implementing technological enhancements to monitor suspicious activity.

FinCEN has 180 days from its release of the AML/CFT Priorities to issue relevant regulations.

ACA guidance

ACA recommends that firms review the AML/CFT Priorities for areas that apply to their business activities, and consider what changes need to be made to their AML program to incorporate these priorities.

How we help

ACA has a number of solutions to help broker-dealers build an effective and compliant AML program.

Please contact your ACA consultant or contact us below to find out how we can help your firm implement these priorities into your AML program.

 Contact Us