Ready to Comply with FinCEN?
-
Have more than $110m AUM or file a Form ADV
-
Registered with the SEC
-
Take investment from third party entities or individuals
What does this mean for me and my firm?
As a covered advisor, you are now required to safeguard the Bank Secrecy Act (BSA) and follow very similar anti-money laundering rules as money service businesses, fintechs, broker dealers, and banks.
-
Design and implement policies & procedures unique to your business
-
Conduct AML training for your employees and perform audits to ensure compliance
-
Capture more AML/KYC data and implement a robust risk-based Customer Identification Program (CIP)
-
Comply with the Travel Rule by storing detailed records and verifying each funds transfer
-
Submit Currency Transaction Reports (CTRs) for any cash transactions
-
Identify and investigate unusual activity and file suspicious activity reports (SARs)
How do I effectively meet my obligations?
While meeting your obligations is of the utmost importance, cost is a key consideration when designing your AML program.
-
Keep legal/consulting costs down - Digitize your AML program to reduce setup, training, and auditing time
-
Keep technology costs down - Don't sign up for expensive automation tools designed for larger organizations
-
Keep operational costs down - Implement digital checks & balances and workflow automation to enable you to run the program internally
80%
Common
Most AML workflows are commoditized. Every firm should not rebuild the wheel.
20%
Unique
There are unique AML risks based on your product offering and your client base.
60%
Cheaper
Digitization + Trusted Advisors + Internal Workflows. We're optimized for your ROI.
What do I do next?
The intention of the regulation is for you and your employees to understand your responsibilities and to do your part to prevent money laundering and terrorist financing (AML/CTF). This is not something that you can 100% outsource.
-
Learn more about the requirements. Register for our newsletter and you'll receive free resources and guidance.
-
Speak with your lawyer or AML Consultant. You'll need to adapt your P&Ps and other agreements. Beat the rush.
-
Build an operating plan. Design a program to meet your obligations and follow your P&Ps.
-
Implement your Program. Design manual processes or leverage a technology platform like Kooltra.
-
Train your Team. Provide AML training to your team and ensure they know their role in meeting your policies.
-
Go Live. Begin following your new processes.
-
Audit. Ideally conduct an audit before the enforcement date.
Subscribe to our Newsletter to receive updates and insights on FinCEN compliance
Who is Kooltra?
Kooltra is a technology company dedicated to delivering cost-effective, highly robust, end-to-end solutions for complex capital markets problems.
We have over a decade of experience helping money service businesses, fintechs, fx brokers, and payments companies to digitize & optimize their Compliance, Treasury, and Trading workflows.
We have leveraged our broad infrastructure to assemble the lowest cost, highest ROI solution on the market for meeting FinCEN's requirements.