In January 2023, the Financial Industry Regulatory Authority (FINRA) released its annual Examination and Risk Monitoring Program report, prominently placing Anti-Money Laundering (AML) compliance among its top regulatory priorities. The report emphasized the need for broker-dealers to improve transaction monitoring, tailor their programs to their risk profile, and adopt a more proactive approach in identifying suspicious activities.

One of the key concerns raised was the lack of customization in AML programs. FINRA found that many firms were relying on generic templates that failed to address the unique risk exposures of their specific business models. It also pointed out deficiencies in the use of automated surveillance tools, which in some cases generated excessive false positives or missed red flags entirely due to poor calibration.

The report called for enhanced training programs, improved quality control over SAR filings, and greater integration between compliance, technology, and operations teams. FINRA also encouraged firms to document the rationale for key decisions, especially when choosing not to file a SAR, to ensure defensibility in regulatory reviews.

This emphasis from FINRA signals a broader industry trend toward accountability and effectiveness rather than mere compliance. For compliance professionals, it means reevaluating legacy systems and investing in technology that supports dynamic risk detection. As regulatory expectations evolve, staying ahead requires continuous improvement—not just in tools and policies, but also in mindset and culture.

Source: 2023 Report on FINRA’s Examination and Risk Monitoring Program
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