Challenges in Implementing Effective AML Compliance and Internal Audit Programs in a Global Enterprise

Author: Sid Valluri Ph.D., CAMS-Audit

Global companies with multijurisdictional footprints, especially those with different lines of business, have some unique challenges in establishing, supervising and auditing an effective know your customer/anti-money laundering (KYC/AML) program. This problem is accentuated in financial services companies where a majority—or at least a significant portion of the products and services—have AML implications. Issues such as local regulatory differences, a focus on business operations, available KYC resources and geographic distance, can make the task of administering an effective program more difficult. That in turn complicates the task of the auditor who has to account for the many differences and ensure that the programs are effective, and despite their variations, faithfully follow their documented procedures.

This paper focuses on the KYC aspects of compliance programs and identifies common issues that arise. It presents a risk-based approach to streamlining them while achieving commercially compatible effectiveness.

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