FINRA Regulatory Notice 18-19 issued May 11, 2018 expands AML Program requirements to include additional risk-based procedures, or the “fifth pillar” required for AML programs under the new FinCEN CDD Ruling Since all AML programs are customized based upon the size and risk of a Mortgage Lender, Broker or Individual Licensee, the application of the “fifth” pillar must be factored into all programs beginning on May, 11, 2018. Therefore all AML programs must be modified …