Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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1/9/2006 Oppenheimer BSA Violations Detailed in New York Stock Exchange Decision
A New York Stock Exchange Panel Decision (05-181) details BSA Violations of Oppenheimer & Company, Inc., primarily in 2002 and 2003. Oppenheimer consented to findings of the Panel without admitting or denying guilt. The Decision is worth the attention of all broker-dealers in demonstrating that examiners may look for compliance beyond the mere letter of the law.  For instance, the firm’s AML Department was staffed by an AML officer and an analyst, but the AML officer also reviewed and responded to customer complaints, regulatory inquiries and trade surveillance for two branch offices.  Given that Oppenheimer employed nearly 1,600 registered representatives in over 100 domestic and foreign branch offices who serviced approximately 360,000 individual customers, the Decision found that the AML Department was not adequately staffed.  In other words, mere appointment of an AML compliance officer is not enough if that officer doesn’t have time to do his or her job. The Decision will be the subject of further analysis in an upcoming Monitor.

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