Customer Identification Program – Compliance Building

LPL Fails in CDD

Doug Cornelius January 29, 2025January 23, 2025 Anti-Money Laundering [+]

LPL Financial LLC, a dually registered investment adviser and broker-dealer, failed to follow its own anti-money laundering policies and procedures regarding its Customer Identification Program and ongoing customer due diligence obligations. The Securities and Exchange Commission and LPL settled on the charges and the $18 million penalty. What can we learn from the case? On … Read more »

FinCEN and Address Confidentiality Programs

Doug Cornelius January 12, 2010January 12, 2010 Anti-Money Laundering [+]

How do you open a bank account when you are hiding from domestic violence? The rules implementing the Bank Secrecy Act require a financial institution to implement a Customer Identification Program that includes procedures that enable it to form a reasonable belief that it knows the true identity of its customers. The rules also require … Read more »