Detecting Hidden Risks: An Investigative Approach to AML Audit in Community Banks

Dan Jackson, CAMS-Audit

The intention of this paper is provide consideration and discussion on the impact of hidden risks within the Anti-Money Laundering (AML)/Bank Secrecy Act (BSA), including the Office of Foreign Assets Control (OFAC), programs of community banks. The collective efforts will hereafter be referred to as the AML program. This paper will explore potential areas in which components of the AML program may be overlooked and expose the institution to unwanted risk. In identifying these potential areas of risk, it is possible to identify processes and procedures to enhance controls over these areas to mitigate those risks that implicates drug cartels or terrorist rings—it also includes activity that might indicate fraud, insider trading, or manipulative trading schemes.”

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