Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks. AML compliance programs are built on a systematic review of a large number of financial transactions. The focus of this review has to be on triggers that identify suspicious transactions or customers. Know Your...
I am a strong proponent of conducting a risks assessment as part of an overall ethics and compliance program. However, I often caution companies to balance benefits and costs, and not to conduct a glitzy, high-priced risk assessment. Instead, I encourage companies to conduct a cost-effective risk and compliance program assessment that focuses on risk, mitigation of such risks and measurement of residual risks. Too...
Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an anti-money laundering compliance program. My suggestion is not designed to promote business or even “scare” companies into addressing this issue – it makes sense...
We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...
