Chapin, Davis, based in Baltimore, MD, agreed to a $50K fine to settle FINRA charges it failed to develop and implement a reasonably designed AML compliance program ("AMLCP").   While containing information primarily relating to customer ID procedures, the firm's WSP's apparently offered little or no guidance on how to comply with most requirements of the Bank Secrecy Act.  FINRA further noted these allegations:

• WSP's contained no provisions on conducting customer due diligence and enhanced due diligence, and insufficient guidance on responding to, and properly documenting responses to, information requests the FinCEN.
• WSP's didn't address how to monitor for and report suspicious activity.
• Firm failed to conduct an adequate independent test of its AMLCP.
• Testing conducted by an independent auditor was deficient, in that it failed to test the firm’s implementation of an SAR surveillance program, AML training program and Bank Secrecy Act requirements, including customer identification procedures.
• Firm failed to establish, maintain and/or enforce a supervisory system and written procedures reasonably designed to record and supervise private securities transactions, and failed to record such transactions.
• Firm failed to keep current all account forms in compliance with SEA Rule 17a-3(17), and NASD Rules 3110(a) and (c). 

This is FINRA Case #2010021065701.   [FINRA Fines & Sanctions for February]