SIE practice questionmediumAML Compliance Program
Every broker-dealer must establish an Anti-Money Laundering (AML) compliance program that includes all of the following EXCEPT:
- ADesignation of an AML compliance officer
- BA guarantee that no illicit funds will ever enter the firm✓ Correct answer
- CIndependent testing of the AML program
- DOngoing employee training
Explanation
Why B — A guarantee that no illicit funds will ever enter the firm
An AML compliance program must include: (1) internal policies and procedures reasonably designed to detect and report suspicious activity, (2) designation of an AML compliance officer, (3) ongoing employee training, and (4) independent testing of the program (audit). No firm can guarantee that illicit funds will never enter (C) — the obligation is to have reasonable procedures to detect and report suspicious activity. The program must also include a Customer Identification Program (CIP).
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