Cordium can undertake a variety of project based services for broker/dealers, based on each individual firm’s specific requirements. Some examples of project work that we carry out on a regular basis, are as follows:
- AML independent audit
- Cordium will conduct the Firm’s annual AML examination that would test and analyze the effectiveness and efficiency of the AML program as it pertains to the firm’s activities. The AML program audit will be conducted in order for you to comply with Conduct Rule 3310(c), which requires the Firm to provide for independent compliance testing of the AML program. The scope of the review will include an assessment of the Firm’s compliance with Conduct Rule 3310, applicable Sections of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001, SEC Rule 17a-8 and the Bank Secrecy Act (“BSA”), and the requirements of the Office of Foreign Assets Control (“OFAC”). Also addressed within the review will be your applicable filing and reporting requirements with the Director of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). A Report will be generated for delivery to FINRA or the SEC during a regulatory examination of the Client./Arranger activities: Firms that provide investment advice to other investment firms or directly to funds, including self-managed funds.
- Mock SEC/FINRA regulatory exam process
- Cordium will work with you to conduct an onsite Mock Examination utilizing materials currently used by the SEC and FINRA in their examination program. This exercise is designed to be as realistic as possible with timing and documentation expectations mirroring the regulators. The goal is to prepare you for the real event in order to eliminate inefficiencies in the your response by identifying weakness in the Firm’s books and records and general operations. who are already regulated to provide investment services, but who do not wish to become AIFMs. This includes hedge funds, private equity or real estate firms advising offshore managers of PE or RE funds.
- Audit preparation
- We can conduct an Audit Prep exercise with which will assist you with the preparation of the files and paperwork that would typically be requested during an examination/audit conducted by the U.S. Securities & Exchange Commission (“SEC”).