AML Independent Audits
Independent AML testing,built for the online era.
American Elm provides AML independent audits for broker-dealers — delivering the objective annual testing FINRA expects, with a specialty in audits and evaluations for BDs launching online platforms. We have guided new broker-dealers entering this fast-growing space from initial structuring through their first offerings.
Who We Serve
Traditional brokerages and technology-forward platforms alike.
Established Broker-Dealers
Firms that need their annual independent AML test performed by experienced, objective auditors — with findings that drive real improvement, not boilerplate.
BDs Launching Online Platforms
Firms building digital onboarding, online offering distribution, or platform-based capital raising — where customer journeys and funding mechanics make AML look different.
New Broker-Dealers
Entrants to this fast-growing space who need an AML program designed correctly from the start, plus readiness reviews before the first examination cycle.
Audit Coverage
What an American Elm audit covers.
FINRA Rule 3310 Independent Testing
The objective, documented annual independent test your AML program requires — scoped to your business model, delivery channels, and customer base.
Online Platform Audits & Evaluations
Specialized audits and evaluations for broker-dealers launching online platforms — onboarding flows, identity verification, funding mechanics, and communications review built for digital distribution.
Gap Analysis & Remediation
Clear, prioritized findings with practical remediation guidance — policies, procedures, and controls that hold up under examination.
New Broker-Dealer Readiness
Readiness reviews for firms entering the online space: AML program design, supervisory procedures, and the documentation examiners expect from day one.
- Customer identification program (CIP) testing
- Onboarding and identity verification flow review
- Transaction and activity monitoring evaluation
- Suspicious activity escalation and SAR processes
- AML training program assessment
- Written supervisory procedures for online distribution
The Engagement
Scope. Fieldwork. Findings. Remediate.
Scope
We define the audit scope with you — business lines, platforms, customer types, and prior findings.
Fieldwork
Testing of your program against Rule 3310 and FinCEN requirements: CIP, monitoring, SAR processes, and training.
Findings
A written report with clear, prioritized findings — practical, documented, and examination-ready.
Remediate
Hands-on support implementing fixes and strengthening the program before your next examination.
The outcome: an independent audit that satisfies Rule 3310, findings you can act on, and a program that stands up when FINRA comes calling — whether your clients walk in or log in.
Common Questions
Frequently asked questions.
Schedule your independent audit.
Annual testing cycle approaching — or a platform launch on the horizon? Let's talk.