The short answer: FINRA publishes a template that helps small firms build the written Anti-Money Laundering (AML) compliance program required by the Bank Secrecy Act (BSA), its implementing regulations, and FINRA Rule 3310. The template is a drafting aid, not a certification and not a substitute for firm-specific judgment. For readers who hold crypto or exchange-linked exposure and use AML posture as part of an investment thesis, the template is a useful checklist of what a regulated broker-dealer is expected to document.
What the template actually is
FINRA describes the template as a resource for small firms to help them fulfill their responsibilities to establish the AML compliance program required by the BSA, its implementing regulations, and FINRA Rule 3310. It supplies text examples, instructions, relevant rules, websites, and other resources useful for developing an AML plan.
That framing matters. The document is guidance and scaffolding. It does not itself create obligations beyond the rules it cites, and it does not guarantee that a completed template will satisfy examiners. FINRA also notes that firms may access all of its guidance on Rule 3310 from its Anti-Money Laundering main page.
The September 8, 2020 update
The template has been revised. One stated change is that it now reflects member firms' obligations under FINRA Rule 3310 in light of the Financial Crimes Enforcement Network's (FinCEN) final rule on Customer Due Diligence Requirements for Financial Institutions, commonly called the CDD Rule.
Additional changes include updated rule citations and resources, with hyperlinks pointing directly to the cited material, plus additional guidance issued since the template was last updated. The page also records that the changes to the AML Template were updated on September 8, 2020, and that the update reflects recent guidance, including the red flags described in Regulatory Notice 19-18 (May 2019).
Read the sequence carefully: the source page dates to July 18, 2018, but the substantive update to the template is dated September 8, 2020. Anyone citing the template should cite the update, not the original page date.
Why this belongs in a crypto thesis file
Long-term holders often treat AML as a compliance cost center. It is also a moat test. A firm that can show a documented, rule-referenced AML program is easier to supervise, easier to bank, and easier to keep listed. The template is one public benchmark for what 'documented' looks like in the broker-dealer context.
Two cautions. First, the template is written for small firms and for the broker-dealer rulebook; it is not a crypto-native standard. Second, the existence of a template says nothing about how rigorously any particular firm applies it. The template describes expectations, not outcomes.
A comparison worth keeping
The distinction between announcement, availability, and implementation is the core analytical habit here.
| Stage | What it means for the template |
|---|---|
| Announcement | FINRA states that the template exists and describes its purpose |
| Availability | The template and its linked resources are published for firms to use |
| Approval | No approval step is described for using the template itself |
| Implementation | Each firm decides how to adapt text examples and instructions to its own business |
Only announcement and availability are supported by the source. Approval and implementation are firm-level and not established by the page.
Worked example (Hypothetical)
Suppose a small firm is reviewing its AML plan and finds a CDD section drafted before the FinCEN CDD Rule was reflected in the template. A reasonable review path, labeled Hypothetical because it is an illustration rather than a documented case, looks like this:
- Confirm the current template reflects Rule 3310 obligations in light of the CDD Rule.
- Check that rule citations match the hyperlinked source material.
- Review whether Regulatory Notice 19-18 (May 2019) red flags are addressed.
- Document the date of the review against the September 8, 2020 update.
Hypothetical: if a firm's plan cites three superseded rule references, that is three items to reconcile before an examination conversation, not a quantified risk figure. No such count is stated in the source.
Checklist for thesis readers
- Does the firm's public AML description reference BSA, Rule 3310, and CDD obligations?
- Is the cited version of any template current relative to the September 8, 2020 update?
- Are red flags from Regulatory Notice 19-18 (May 2019) acknowledged in policy language?
- Is the firm small enough that the small-firm template is the right benchmark?
What the source does not say
The page does not state whether the template is mandatory, does not describe examination outcomes, and does not quantify compliance costs or penalties. It does not address crypto assets, exchanges, or custodians specifically. It does not state that any firm has adopted the template, and it does not compare the template with other regulators' guidance. It also does not provide a verification date beyond the September 8, 2020 update note, and does not say whether further revisions are planned.
For an investment-thesis file, the honest conclusion is narrow. The template is evidence that a public, rule-referenced AML drafting benchmark exists and was updated to reflect the CDD Rule and Regulatory Notice 19-18 red flags. That supports a compliance-maturity question you can ask of any firm. It does not support a claim about any specific company's AML quality, and it should not be used to infer anything about token prices.