The best AML compliance programs are found in organizations that have a strong tone at the top, clear understanding of regulatory issues, and a willingness to seek advice from compliance professionals.Īlignment of resources and risks. Research has shown that ethical dilemmas lead to non-compliance in situations involving isolated decision-making or in groups with a singular mindset. Leadership must demonstrate a commitment to compliance infrastructure and an environment where employees are encouraged to raise issues and ask questions. Boards and senior management must direct and nurture a compliance culture. A culture of compliance in any organization cannot be achieved solely by corporate policies or edicts. The following steps characterize top-performing AML compliance programs: Fortunately, institutions can enlist expert help to enhance their compliance and take their AML programs from good to great. For resource-constrained organizations, staying up to date and meeting these requirements can seem like an impossibly high bar to clear. State, federal and international financial services regulators have high expectations for customer due diligence (CDD) and anti-money laundering/countering the financing of terrorism (AML/CFT) programs. Sanctions, for example, are an area where requirements frequently change. Regulators are holding institutions to evolving higher standards. In 2019, the number of SARs that depository institutions, money services businesses, casinos and other entities filed was 38% higher than in 2015. According to the Financial Crimes Enforcement Network (FinCEN), the number of suspicious activity reports (SARs) related to money laundering has risen steadily in each of the past five years. Perpetrators of illicit financing are not giving up or going away. As financial institutions strive to keep up with evolving regulations and a growing number of financial crimes each year, “good enough” is quickly becoming insufficient. What makes for a great anti-money laundering compliance program? This is not a pie-in-the-sky idea.
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