Provide a response to each question by choosing the appropriate radio button. Upload evidentiary supporting documents where requested. At the beginning of each section you will be provided with a list of the information that may be requested in that section. Use the print icon to assist you in gathering and placing the potentially relevant materials into an easily accessible location.

Only one user can be logged in at a time. If you receive "Another User is Currently Logged In" please wait until the other user has logged out. If you believe you received the message in error, please close and reopen your browser before attempting another login.

You may exit AML Test Online and resume from where you left off (the last question answered). Always choose the "Save and Continue" before exiting the application or before closing your browser. If you are ever unsure if a document has been uploaded, check the folder on the left side of your screen

The questionnaire must reflect “Completed” before BD Financial Services Group will begin the test review. Answer all questions and satisfy all upload requests until you receive the “Thank You” notification at completion. Upon completion of the test you will receive an email notification with a link to access your report.

In accordance with requirements of the Bank Secrecy Act (31 U.S.C. 5311, et seq.) amended to include Title III of the U.S. Patriot Act ("the Act") promulgated by the Department of Treasury, each FINRA member firm must develop and implement a written anti-money laundering program reasonably designed to achieve and monitor the member's compliance with the requirements of the Bank Secrecy Act, and the implementing regulations promulgated thereunder by the Department of the Treasury. Each member's anti-money laundering program must be approved, in writing, by a member of senior management. The anti-money laundering programs required by this Rule shall, at a minimum:

1. Establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) and the implementing regulations thereunder;
2. Establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act and the implementing regulations thereunder;
3. Provide for annual (on a calendar-year basis) independent testing for compliance to be conducted by member personnel or by a qualified outside party, unless the member does not execute transactions for customers or otherwise hold customer accounts or act as an introducing broker with respect to customer accounts (e.g., engages solely in proprietary trading or conducts business only with other broker-dealers), in which case such "independent testing" is required every two years (on a calendar-year basis);
4. Designate and identify to FINRA (by name, title, mailing address, e-mail address, telephone number, and facsimile number) an individual or individuals responsible for implementing and monitoring the day-to-day operations and internal controls of the program (such individual or individuals must be an associated person of the member) and provide prompt notification to FINRA regarding any change in such designation(s);
5. Provide ongoing training for appropriate personnel; and
6. Include appropriate risk-based procedures for conducting ongoing customer due diligence, to include, but not be limited to:
   1. Understanding the nature and purpose of customer relationships for the purpose of developing a customer risk profile; and
   2. Conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information. For purposes of paragraph (f)(ii), customer information shall include information regarding the beneficial owners of legal entity customers (as defined in 31 CFR 1010.230(e)).

BD Financial Services Group, LLC ("BDFSG") performs independent testing pursuant to the items enumerated above for the purpose of meeting the minimum standards set forth below. However, our review includes requesting additional items to assure that the review incorporates "best practices". The questionnaire, document request, potential interview and related notes, evaluating the minimum standards set forth below, as well as broadening the inquiry with a request for additional supporting evidence comprise a more comprehensive review of a firm's AML compliance program ("the Test"). The Test begins with a quote questionnaire followed by a detailed operations questionnaire and a document request specific to your firm's operations and activities to determine the potential risks associated with of your firm being used for money laundering; a comprehensive risk-based approach. The questionnaire, documents and information provided, which may include notes to telephone interviews and/or supplemental information requested from your AML compliance officer will comprise the materials reviewed to issue a comprehensive AML compliance program Test report. The items delineated below are the established minimum standards for the scope of an AML compliance program review:

1. Evaluating the overall integrity and effectiveness of your firm's AML compliance program;
2. Evaluating your firm's procedures for BSA reporting and recordkeeping requirements;
3. Evaluating the implementation and maintenance of your firm's CIP program;
4. Evaluating your firm's customer due diligence (CDD) requirements;
5. Evaluating your firm's transactions, with an emphasis on high-risk areas;
6. Evaluating the adequacy of your firm's staff training program;
7. Evaluating your firm's system, whether automated or manual, for identifying suspicious activity;
8. Evaluating your firm's system for reporting suspicious activity;
9. Evaluating your firm's policy for reviewing accounts that generate multiple SAR filings;
10. Evaluating your firm's response to previously identified deficiencies.

Your firm's responses to the questionnaires are designed to provide BDFSG with information necessary to compose a customized test questionnaire and document request that is relevant to your firm's business operations and the activities in which it engages. After a thorough review of the information provided, BDFSG will issue a report to senior management on the findings and conclusions of your firm's AML compliance program, as is required pursuant to the Acts.

The findings and conclusions noted in the report are based on a review of the answers to questions, evidentiary supporting documents and affirmations submitted through AML Test Online. To assure the highest level of test integrity, BDFSG will not typically accept submissions subsequent to the questionnaire having been completed; evidence provided should be adequate to demonstrate compliance. If the firm finds that additional materials exist that would have altered the findings or conclusions such information should be recorded in the minutes of a meeting held to review the report.

BDFSG is independent as defined in the Securities Exchange Act; no personnel performing an independent test for a firm shall have any dealings with the firm, or any person related in any way to the firm, that would jeopardize its independence.

Unless requested under subpoena, BDFSG shall maintain the confidentiality of the report and all information provided. BDFSG has no obligation to report its findings or conclusion to any regulatory authority or law enforcement agency, except as noted immediately above, and shall not do so voluntarily; this report shall not be released to any third-party without the express written consent of the firm being tested.

The firm understands that according to the terms in the engagement letter the final price may be increased as a consequence of the firm having opened more than 50 new accounts or having more than 20 registered personnel subject to AML training during the year being tested. The final price may be reduced if the firm participates in our referral program. Full details of our privacy, discount, refund and other policies can be found in the Disclosures section of the BDFSG website.