How Audit Departments can Develop an Effective AML Program

Author: Thomas Alessandro, CAMS-Audit

When someone in the Banking community asks you what you do for a living, do you find yourself whispering, “I audit my firm’s AML controls?” We have all seen the head lines.

Public opinion of large banks is very low these days and headlines announcing multi-million dollar fines for AML (Anti Money Laundering) violations do not help the cause.

With a growing global terrorist and organized crime threat, regulators are focused on AML and related topics such as USA Patriot Act, Bank Secrecy Act and OFAC (Office of Foreign Assets Control). Firms around the world have increased their resources to protect against money laundering and terrorist financing. In a 2013 study conducted by Veris Consulting5, nearly 66% of the survey’s 284 respondents (72% Bank, 12% Broker/Dealer, 16% other) reported that their AML and OFAC compliance budgets have increased over the last three years. The majority of resources have been appropriated to the control processes in the lines of business and compliance departments. Firms should also recognize that Audit is the last line of defense that provides an independent review of the control environment against various AML/OFAC risks.

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