Institutional brokerage anti‐money laundering detection scenarios ‐ Filling the gaps

Certain institutional trading operations executives of major broker‐dealers currently are indicating that there is a paucity of guidance from regulators and others on the potential characteristics of anti‐money‐laundering activities in their specific business areas. Because of requirements to file suspicious activity reports with regulatory authorities where these enterprises suspect potential money‐laundering activities, these executives are trying to build and grow the best possible methods of detection to detect potential instances of money laundering, especially where they may have little information as to the identity of the parties who are originating transactions in their institutional contexts. Because of these issues, the existing securities industry AML guidance that is available must be analyzed carefully, keeping in mind the need to construct new scenarios addressing the specific circumstances of the institutional brokerage context.