• NASD Proposal to Amend Rules on AML Compliance
  • July 12, 2005
  • Law Firm: Reed Smith LLP - Pittsburgh Office
  • On June 29, 2005, the SEC issued for comment a set of proposals by the NASD that would amend the NASD's requirements on Anti-Money Laundering (AML) Compliance Programs (Rule 3011), and adopt new related interpretive material ("IM"), to: (1) require each member to conduct an independent test of its AML program on an annual basis (or, in certain cases, every two years); (2) clarify which persons will not be considered to be independent for purposes of Rule 3011(c) (and therefore would not be eligible to conduct the test); and (3) require a member to review, and if necessary, update, the accuracy of its AML compliance person information on a quarterly basis.