The SEC, CFTC and FINRA each announced that they had settled enforcement proceedings against a brokerage firm arising out of alleged deficiencies in the firm’s anti-money laundering (AML) compliance program and its failure to file suspicious activity reports when required to do so by the Bank Secrecy Act (BSA). Although investment advisers are not among the financial institutions subject to the BSA, the settlement orders provide valuable insight into how closely regulators scrutinize firms’ compliance policies and procedures – particularly with respect to AML – and their expectations that compliance programs be tailored to firms’ specific operations and risks. This article synthesizes the key facts from the SEC, CFTC and FINRA settlement orders, including the firm’s alleged violations and the sanctions imposed on it, with additional insights from an industry practitioner with expertise in AML compliance. See “Lessons Private Fund Managers Can Learn From U.S. Bancorp’s Settlement of AML Violations” (Apr. 26, 2018). See also our three-part series on tailoring a compliance program: “Why Fund Managers Should Customize” (Jul.  16,  2020); “What Fund Managers Should Consider” (Jul. 23, 2020); and “When Fund Managers Should Review and Update” (Jul. 30, 2020).