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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.)
To understand the mindset of a bank regulator approaching an AML retail-bank audit, let's take a step back before moving into the specifics.
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