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2016

December 2016

How are you providing current AML and related issues to your FI?
Via internal newsletters and related vehicles
12%
3
In your annual bank-wide training
23%
6
Both A and B
54%
14
Neither
12%
3

November 2016

What is the best approach to mitigate the risks of virtual currencies?
Strict regulation
58%
133
Prohibition
12%
28
Strict enforcement
25%
57
Other
6%
13

October 2016

Is your board of directors actively engaged in AML oversight?
Yes
71%
112
No
29%
45

September 2016

Will this document improve the current AML environment in the U.S.?
Yes
61%
80
No
39%
51

August 2016

What is your organization’s greatest KYC challenge?
Identification of beneficial ownership
27%
52
Locating required KYC information
4%
8
Understanding the risks identified
9%
17
All of the above
60%
115

July 2016

Does your institution review money laundering risks at a transactional level?
Yes, at every transaction
77%
234
Yes, only when a customer trades new goods
1%
4
Not unless there are concerns about the customer or trade
17%
53
No
5%
14

June 2016

Which sanctions-related issue is most troublesome to your FI or firm?
Sectoral sanctions
25%
58
Risk assessment
43%
99
Training
15%
34
Iranian sanctions
17%
40

May 2016

With regard to cybersecurity, my financial institution has…
Taken steps to bring our IT, fraud and AML efforts closer together
65%
46
Started to talk formally about some kind of joint enterprise-wide effort
24%
17
Done little or nothing to create a cybersecurity plan
11%
8

April 2016

To what extent are you staying current on AML/CTF legal and regulatory developments on a weekly basis?
5 percent of the time
14%
31
10 to 25 percent of the time
21%
45
25 to 50 percent of the time
16%
35
More than 50 percent of the time
30%
66
Not enough
19%
41

February 2016

Does your institution have a strong culture of compliance?
Yes
80%
292
No, our compliance culture needs improvement
20%
71

January 2016

In the next 16-20 months, I expect to see AML regulatory enforcement action…
Increasing
90%
425
Decreasing
3%
12
Staying the same
7%
34

2015

December 2015

Does your institution proactively query the name(s) of known or suspected attackers in your systems after a terrorist attack?
Always
66%
78
Sometimes
23%
27
Never
11%
13

November 2015

Can you name and explain the roles of the government agencies responsible for combating terrorist financing?
Yes
85%
168
No
15%
30

October 2015

Have you talked to your management or consulted an outside lawyer about how to limit your personal liability for compliance failures?
Yes, I have spoken to management
8%
10
Yes, I have spoken to both
7%
9
No
73%
90
I have not, but I plan to
12%
15

September 2015

What is the biggest non-money laundering issue facing your institution?
Sanctions
30%
218
Cyber-crime
51%
367
Human trafficking
7%
49
Elder abuse
12%
87

August 2015

Does your financial institution (FI) participate in 314(b) Voluntary Information Sharing?
Yes, it has benefited our FI tremendously
61%
94
No, the process is too time-consuming
15%
24
No, but we are considering it
12%
19
Yes, but we do not know how to use the information
12%
18

July 2015

What does your FI do to effectively manage NPOs?
Place appropriate policies, controls and procedures
43%
42
Identify and assess their money laundering and terrorist financing risks
34%
33
Identify and assess the risk mitigation measures applied by the NPO
18%
18
Develop a constructive working relationship with the NPO
2%
2
None of the above
3%
3

June 2015

As we approach Mid-Year 2015, the biggest AML challenge is:
Hiring and retaining qualified staff
27%
82
Measuring and mitigating risk
24%
74
Staying current with terrorist financing techniquese
21%
65
Understanding regulatory expectations
18%
56
Ensuring “tone at the top” for AML
9%
27

May 2015

So-called "de-risking" still confuses the AML community. What is the most logical strategy to address this?
A true risk-based approach
38%
211
Additional government guidance
5%
27
An International Summit with bankers, law enforcement and regulators
3%
19
All of the above
54%
300

April 2015

Your financial institution’s relationship with law enforcement is:
Excellent and involves regular contact
18%
2
Very good
36%
4
Okay—it could be better
27%
3
We have little helpful interaction with law enforcement
18%
2

March 2015

How does your financial institution protect itself from cybercrime?
By utilizing a sophisticated fraud detection system
0%
0
Training employees to be aware of infected emails
0%
0
Being cautious of fake virus scanners and getting the best protection
0%
0
All of the above
100%
8

February 2015

What does your institution do to identify and help prevent credit/debit card fraud?
Cyber threats
0%
0
Identifying larger-than-normal transaction dollar amounts
0%
0
Provide education to customers on protecting card-related information
0%
0
Training all employees on how to spot a fraudulent card activity
0%
0
All of the above
100%
5

January 2015

What will be a top issue/hot topic for 2015?
Cyber threats
38%
112
ISIS
22%
65
Banking marijuana entities
16%
48
Russian sanctions
11%
33
De-risking
8%
23
Examination Criticisms
5%
16

2014

December 2014

What is your financial institution doing to identify supporters of ISIS or other terrorist organizations?
Checking IP logins in or near areas of conflict
1%
1
Looking for periods of transaction dormancy
0%
0
Investigating ATM cash withdrawals in or near areas of conflict
1%
1
Inspecting wire transfers to areas of conflict
23%
18
Checking social media postings
1%
1
All of the above
44%
35
G. At this point we haven’t created a specific response to ISIS
30%
24

November 2014

The major cause of "de-risking" is:
A financial institution’s inability to create appropriate controls and manage the customer that has been declared "high risk."
31%
83
The financial institution overreacting to a category of customer risk and simply exiting the relationships.
29%
78
Financial institutions believing there are conflicting and changing regulatory expectations that affect maintaining high-risk customers.
24%
65
None of the above.
17%
45

October 2014

Your annual BSA/AML program training is:
Excellent
21%
27
Satisfactory
49%
63
Stale
11%
14
Needs improvement
19%
25

September 2014

What are the major challenges for your institution in banking MSBs?
Regulation of MSBs appear inconsistent
7%
14
Despite proper due diligence and oversight, regulatory expectations are hard to discern
15%
32
Once any category of entity is declared “high risk,” it is difficult to gain acceptance for lowering that risk
9%
18
All of the above
70%
147

August 2014

It is now mid-year 2014, your biggest concern for the next six months is:
Outcome of our next AML examination
25%
110
Convincing management to increase staffing/resources
25%
111
Achieving a better understanding of virtual currency
15%
69
Ensuring proper controls for high-risk accounts
35%
156

July 2014

Do you own any bitcoins?
No, and I can’t imagine I ever will
76%
358
No, but I would like to
17%
80
Yes
8%
36

June 2014

Has your financial institution been affected by the alleged fraudulent business practices tied to the World Cup stadium building in Brazil?
Yes
10%
17
No
69%
112
Don’t know
21%
34

May 2014

For U.S. financial institutions, during your most recent AML exam, what was the major focus of the examiner?
SAR process
19%
63
Risk Assessment
35%
120
AML Resources/Training
17%
57
Policies and Procedures
23%
77
Other
6%
22

April 2014

What drives funding for AML compliance resources?
Reputational Risk
22%
112
Enforcement Actions
45%
228
Understanding of the AML compliance role by management
24%
120
Audits
10%
49

March 2014

How often does your institution update your medium- or low-risk population?
Annually
47%
80
Every two years
15%
25
Every three years
19%
32
Not sure
19%
32

February 2014

Late last week, FinCEN issued guidance, in coordination with the Department of Justice, on how financial institutions could bank marijuana businesses. This guidance:
Will make it MORE likely that FI’s will bank those businesses
28%
39
Will make it LESS likely that FI’s will bank those businesses
28%
39
Further confuses the issue
45%
63

January 2014

With the media stories on enforcement actions, what do you think is the major cause of financial institution AML deficiencies?
Lack of resources
6%
20
Inadequate culture of compliance
18%
58
Confusion about regulatory expectations
7%
21
All three
69%
219

2013

December 2013

As 2013 comes to a close, the AML community’s biggest challenge was:
Lack of Sufficient Resources
16%
49
Ensuring “Tone at the Top.”
8%
23
Rapidly Increasing Regulatory Expectations
28%
82
All three were Equal
48%
144

November 2013

The U.S. Treasury bureau, FinCEN, has just issued additional guidance and encouragement regarding information between financial institutions. Do you believe information sharing for AML issues:
is adequate
7%
17
works well
7%
17
needs more work
39%
89
must also include enhanced sharing with the government to be truly effective
47%
107

October 2013

How is AML, Fraud and Cyber-security treated at your institution?
Completely separate
61%
138
Unified
21%
47
Matrix
18%
41

September 2013

As a compliance officer, have you ever filed a currency transaction report or suspicious activity report on a customer that you later found was arrested, indicted or convicted of a crime?
Yes
31%
173
Yes, more than once
31%
173
Never
23%
127
Not sure
16%
89

July 2013

Regulators, FATF and the overall AML community support the concept of the “Risk Based Approach.” So, is it working?
Yes
58%
234
No
10%
42
Too Soon to Know
26%
107
Not sure
6%
23

May 2013

Have financial sanctions against Iran been effective as a national security tool?
They have been effective
19%
65
They have been somewhat effective
48%
165
They have not been effective
26%
89
Not sure
8%
28

April 2013

Foreign-issued prepaid cards are:
High risk
89%
571
Low risk
2%
16
Medium risk
7%
45
Not sure
2%
10

April 2013

Does your institution have the proper IT measures in place to prevent or mitigate a cyberattack aimed at stealing proprietary data or money directly from accounts?
Yes
59%
72
No
9%
11
Not sure
24%
30
Somewhat
8%
10

March 2013

Does your company sanction screen the payee of official checks?
cashier’s checks
44%
66
treasury checks
11%
17
money orders
12%
18
don’t know
33%
50

February 2013

Has transparency in cover payments increased since the introduction of form MT 202 COV?
The form has increased transparency.
36%
80
The form has not increased transparency.
32%
71
The form has been somewhat effective since not all financial institutions use it.
26%
58
I’m not sure.
5%
11

January 2013

Risk Assessments are an essential part of any financial institution’s AML procedures. My FI’s risk assessment is updated:
Monthly
12%
22
Bi-Annually
10%
19
Annually
59%
109
When events warrant (e.g., new products)
18%
34

2012

December 2012

What will be the biggest challenge for AML professionals in 2013?
Regulatory expectations
42%
152
Expanding scope of duties
17%
60
Not useful
20%
72
Retaining and/or hiring qualified staff
21%
75

October 2012

How useful will FinCEN’s BSA IT Modernization Program be once it is completed?
Very useful
51%
35
Somewhat useful
14%
10
Not useful
7%
5
Don’t know
28%
19

September 2012

The events of September 11th brought rapid changes to financial regulations worldwide, but were those changes generally the correct ones or should legislation have followed a different path?
Yes, the regulations were appropriate.
64%
52
No, changes were needed but the laws should have addressed different financial activities.
36%
29

August 2012

Do you think that the New York State Department of Financial Services accusations against Standard Chartered Bank will eventually be shown to be overzealous?
Yes
42%
101
No
58%
141

August 2012

The U.S. Department of the Treasury published a model agreement (with France, Germany, Italy, UK and Spain) to implement the information reporting of FATCA. Do you agree with this approach?
Yes
78%
57
No
22%
16

July 2012

Do you plan on attending FinCEN’s hearing on its Customer Due Diligence proposal?
Yes
29%
25
No
71%
62

May 2012

In February, the Internal Revenue Service issued Foreign Account Tax Compliance Act (FATCA) proposed regulations, which aim to require non-U.S. based financial institutions to report directly to the IRS information about financial accounts held by their U.S. taxpayer clients, among other things. A good portion of the proposed regulations were intended to address industry concern regarding complexity and depth of the requirements and, cost burden. Do you believe the proposed regulations addressed those implementation issues?
Yes, I believe the proposed regulations have eased the burden for foreign financial institutions’ implementation of FATCA.
17%
10
No, I don’t believe the proposed regulations have eased the burden for foreign financial institutions’ implementation of FATCA. The challenges, such as cost of implementation and complexity, remain the same.
49%
29
I believe the proposed regulations have eased the burden of implementation in some areas and, increased the burden of implementation in other areas.
14%
8
I’m not sure.
20%
12

April 2012

How likely are you to call or directly contact law enforcement about a suspicious activity report (SAR) you filed on a client or transaction that feel you is particularly suspicious or egregious?
I have already informed law enforcement in the past about a SAR I filed.
52%
77
I have never directly contacted law enforcement about a SAR I filed. However, if I felt that a particular SAR needed immediate attention, I would not fail to contact them.
35%
52
It never occurred to me to call law enforcement about the filing of a SAR.
9%
13
I would not feel comfortable contacting law enforcement about the filing of a SAR.
5%
7

March 2012

The U.S. Department of State released the latest version of its International Narcotics Control Strategy Report (INCSR) on March 7. The report lists major money laundering countries and includes country-to-country analysis of certain anti-money laundering regimes. How useful are these reports to compliance officers?
The reports are very useful. I use the reports to assist my financial institution in its development of country risk analysis, training, or for other purposes.
44%
18
The reports are somewhat useful. A lot of the information, such as its list of major money laundering countries, is well known to most compliance officers or, I find a lot of the information repetitive.
29%
12
The reports are not useful. The information does not pertain to my particular financial institution or I find the information to be too general.
7%
3
I am not familiar with the reports.
20%
8

March 2012

On February 16, the Financial Action Task Force announced its revised Recommendations and added tax crimes as a predicate money laundering offense. In your opinion, once that change is incorporated into your jurisdiction’s laws how will that affect your compliance program?
The additional compliance demands will translate into the need for more resources, such as staff and a larger budget.
38%
36
I don’t anticipate any great changes.
31%
29
Tax crimes are already a predicate money laundering offense in my country.
22%
21
Not sure.
9%
8

February 2012

President Obama recently signed a budget defense bill that will block foreign banks that “knowingly” facilitate the purchase of oil through the Central Bank of Iran (CBI) from the U.S. financial system. Will the law be:
Effective
41%
124
Note Sure
26%
78
Not Effective
33%
99

January 2012

As you prepare for 2012, the biggest challenge to the AML community is:
Adequate Resources
24%
51
Responding to Regulatory Examinations
8%
16
Understanding how various products are used for money laundering
12%
25
Training
5%
10
All of the above
51%
107

2011

December 2011

Are broker dealers ready for the July enforcement deadlines of two sets of federal rules that will broadly expand their know-your-customer duties?
Yes
27%
15
No
73%
41

November 2011

Have you followed FinCEN’s proposed new SAR Form? If so, do you:
Support
32%
16
Oppose
34%
17
Need More Time to Review
34%
17

October 2011

October 26 marks the ten year anniversary of the USA PATRIOT Act. Has it made us safer?
Yes
73%
145
No
27%
54

October 2011

Do you agree with FinCEN’s final rule to implement section 104 (e) of the Comprehensive Iran Sanctions, Accountability and Divestment Act (CISADA)?
Yes
64%
50
No
14%
11
Undecided
22%
17

September 2011

What percent of your SARs/STRs are originally sourced by your:
transaction monitoring system(s)
29%
27
list-screening system(s)
23%
21
front-line employees noting suspicious activity
28%
26
other
20%
18

August 2011

AML duties seemed to have greatly expanded in recent years, but have they throughout the industry? In your current AML role are you also responsible for:
Fraud
16%
52
Sanctions
14%
47
Corruption
5%
17
All three
58%
190
None of the above
7%
22

July 2011

At last week’s ACAMS European Conference, many government officials expressed support for requiring financial institutions to monitor domestic PEPs. Today, do you monitor activities for domestic PEPs?
Yes
61%
86
No
39%
54

June 2011

Should countries develop AML regulations to track and prosecute the use of the Internet to move illegal proceeds?
Yes
97%
126
No
3%
4

June 2011

Are your regulatory examiners formally recommending increased board of directors’ involvement in compliance-related decisions?
Yes
74%
51
No
26%
18

May 2011

With the death of Osama Bin Laden, will the threat of terrorist financing:
Increase
85%
132
Decrease
15%
23

May 2011

Do you have a cybersecurity program that formally includes the AML division?
Identity theft
14%
3
Credit card fraud
86%
18

April 2011

What is the most common risk your financial institution has faced when providing the prepaid card product to customers?
Identity theft
24%
21
Credit card fraud
16%
14
Income tax evasion
6%
5
Money laundering
43%
37
Terrorist financing activities
10%
9

March 2011

There have been reports that FinCEN is proposing to severely limit or eliminate state access to BSA Data.State officials indicate that this would severely hamper money laundering investigations. Do you support FinCEN’s proposal?
Yes
13%
10
No
87%
68

March 2011

If the States do not have access to the BSA data, do you think it will have an impact on your AML program?
Yes
69%
54
No
31%
24

March 2011

Which section of the ACAMS web site do you find the most useful?
Forums
15%
33
Resources
12%
26
Publications (ACAMS Today and Connection)
7%
15
Member profiles
31%
67
Chapter pages
9%
19
Conferences and Events
27%
59

February 2011

A recent report found that 63 percent of 500 respondents dropped an account or severed business ties over FCPA or OFAC concerns in the last 3 years. Have you in the past year:
Dropped an account due to FCPA concerns
15%
4
Stopped a merger due to OFAC compliance concerns
4%
1
Not been affected by OFAC or FCPA concerns
81%
21

January 2011

How would you rate your relationship with your local law enforcement?
Excellent
48%
53
Good
32%
35
Room for Improvement
11%
12
Poor
9%
10