What's included
Independent test
Testing of your AML program with a written report of findings and recommendations.
Program design
AML policies and procedures built for your business model and customer base.
OFAC screening
Screening procedures and documentation for sanctions compliance.
Customer identification
CIP procedures and testing of how they work in practice.
Suspicious activity
Review of red-flag monitoring and escalation.
Remediation
Practical fixes for any gaps the test finds.
How often? FINRA Rule 3310(c) requires independent testing each calendar year for most firms. Firms that don't execute transactions for customers, hold customer accounts or act as an introducing broker for customer accounts may test every two years.
Why firms choose RND
Senior attention
You work directly with principals who have been in the securities industry since 1985, not a rotating junior team.
Testing you can stand behind
A written report that shows what was tested, what was found and what changed.
A CPA on your books
Debasish Banerjee is a Certified Public Accountant with four decades of broker-dealer accounting and financial reporting.
Supervised AI, human review
AI agents track rule changes and deadlines and prepare first drafts; an experienced professional reviews every output, consistent with FINRA Regulatory Notice 24-09.
How we work
1. Discovery call
A no-cost conversation about your business model, your regulators and what's due next.
2. Gap assessment
We review your procedures, books and records, filings and exam history against current rules.
3. Build the program
Policies, calendar and set-up sized to your firm, priced up front.
4. Ongoing oversight
Due-date alerts, filings, annual reviews and a senior professional on call when regulators ask.
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Questions firms ask
Who can perform the independent test?
FINRA Rule 3310 requires the test to be independent. Qualified outside parties can perform it, as can member personnel other than the AML compliance person, anyone who performs the functions being tested, or anyone who reports to either of them.
What happens after the test?
You receive a written report. We help you remediate any findings and keep the documentation examiners ask for.
Need your AML independent test?
Talk with Debasish Banerjee, CPA, in the securities industry since 1985. A principal replies within one business day.
Request an AML test →General information, not legal advice. RND Resources, Inc. is a business consulting firm, not a CPA firm or law firm, and is not affiliated with FINRA or the SEC.