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.
