One of our clients came to us with this question: “How do we ensure our brokerage is capturing all non-physical customer addresses in order to prevent violation of FINRA Anti-Money Laundering rules?”

Pandia, our core product, has rules in place that monitor account activity for customers who cannot provide a physical address. Last year the United States Postal Service began allowing Commercial Mail Receiving Agency (CMRA) addresses to appear exactly like a real street address, though they are in fact PO Box addresses.

Patriot Act section 326 outlines Customer Identification Program (CIP) rules requiring financial institutions to collect a residential or business street address for each account owner. The challenge before us was identifying these CMRA addresses in a few short months to prevent a possible compliance gap.

Ultimately our solution was to leverage Accuzip, a company that provides mailing software to identify these CMRA addresses. We now receive a monthly list of all CMRA addresses registered with the United States Postal Service. By importing this data into Pandia we are able to validate physical addresses on a regular basis. We’ve also implemented a daily report to flag addresses for review.

Our client was pleased with the results: “Terrapin was able to partner with Accuzip to provide a robust and nimble CMRA solution to solve for a risk to all firms required to collect and verify a physical address for their customers.”

“Terrapin was able to partner with Accuzip to provide a robust and nimble CMRA solution to solve for a risk to all firms required to collect and verify a physical address for their customers.”

This is one of many examples demonstrating our ability to swiftly and efficiently help our clients adapt to the ever-changing regulatory demands of the industry. Check out our trade surveillance and compliance solutions to learn more about how we can help your firm mitigate risk and remain compliant.

FINRA Audit Guide
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