Anti-Money Laundering Compliance Program
FINRA member firms are required to establish and implement written policies, procedures, and internal controls designed to achieve compliance with the following reporting and recordkeeping requirements:
• To record cash purchases of negotiable instruments between $3,000 and $10,000 in a Monetary Instrument Log (MIL) and to maintain these records for a minimum of five years.
• To report to FinCEN any cash transactions in a single day exceeding $10,000, whether conducted in one transaction or several smaller ones, using the U.S. Treasury’s Currency Transaction Report (CTR).
• To file a Suspicious Ac