Broker-dealers look to enforcement actions to understand Finra's AML priorities. BDs may end up scouring their customer records to see if they have similar documentary issues … and that could draw funds and attention away from priorities identified in the National Strategy for Combatting Terrorist and Other Illicit Financing.
2,301,163 SARs were filed in 2019 which is an increase of 6% from 2018 levels. Depository Institutions filed 48% of all SARs, MSBs accounted for 37% and Securities/Futures filed 9%.