Distributed Ledger Technology For The Securities Industry– In addition to general information, during this LawCast series I have been summarizing a report issued by FINRA in January, 2017 discussing the implications of DLT for the securities industry, including FINRA member broker dealer firms. In the report, FINRA specifically discussed some major areas of consideration. In these last two LawCasts in this series, I have been going through each of those topics as summarized in the FINRA report. Related to Anti-Money Laundering and Customer Identification Programs – DLT allows for global and anonymous participation, and accordingly practices and regulations will need to address anti-money laundering (AML) and customer identification obligations (CIP). The Bank Secrecy Act of 1970 requires controls and procedures to detect and prevent money laundering. FINRA Rule 3310 addresses AML obligations…
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