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Auditing the Effectiveness of Your AML Program
The Federal Reserve Board and the New York Department of Banking have adopted a strict-review standard in their evaluation of the effectiveness of the Anti-Money Laundering (AML) compliance programs of financial institutions. Recent enforcement actions demonstrate that regulators pay particular attention to the effectiveness of Suspicious Activity Reporting (SAR) and Currency Transaction Reporting (CTR) as key components. In addition, an effective audit program must focus on the other essentials: Know Your Customer (KYC), Training, and Testing. How can you be sure that the institution you advise is prepared for a money laundering audit?
While the specifics on how best to accomplish this will depend on the customer base of and products sold by the institution, several constants apply to most retail operations. (Institutional customers present their own challenges and are not specifically addressed in this article.)
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New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.
Law Firms are Reducing Redundant Real Estate by Bringing Support Services Back to the Office
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Each stage of an attorney's career offers opportunities for a curriculum that addresses both the individual's and the firm's need to drive success.