Independent Testing – Getting this Five Pillars Requirement Right
The reputation of a financial institution (FI) relies heavily on the conceptual soundness of its BSA/AML compliance program. Furthermore, the integrity of a FI’s compliance department depends on its ability to identify gaps and deficiencies in its compliance program. A functional way to identify gaps and deficiencies in a BSA/AML compliance program is through independent testing (one of the five pillars of an effective BSA/AML compliance program[i]).
Investigations – they all start with context
This post is part of our occasional series on AML program fundamentals which focuses on refreshing foundational knowledge for experienced members of the AML community and providing an introduction to key topics for those new to the subject.
Information Sharing – the Value and the Challenges
Information Sources Financial service companies (FIs) have a wide variety of information about their customers. Some of it is personal data, gathered at account opening or as part of a specific transaction, such as a loan application; some of it is transaction data gathered to balance accounts and prepare customer statements; and some of it is captured to make required reports to government agencies. In one way or another, much of this data is subject to privacy rules. In the US there are various privacy laws at the federal and state level; in other countries, the laws may be country specific or part of a group of countries such as the European Union.
