If you really want to learn how not to run an AML Department (or a financial institution, for that matter) just read this US Senate Report on HSBC. Great learning tool.
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It has been over ten years since the enactment of the USA PATRIOT Act shone the spotlight over all financial institutions and their AML, BSA, CFT and regulatory compliance programs.
Throughout this time much has been written about the rules and regulations that apply and do not apply to each type of financial institution, the perceived and real threats of non-complying with them, and the dozens of cases in which institutions have failed to meet the expected standards and suffered the consequences. In the case of MSBs, a lot has also been written about the difficulties they have faced in obtaining and retaining banking relationships, which continue to this day. Very little, however, has been written by compliance officers about what the world looks like from within their organizations. Understandably so, one might say, given that it may be inappropriate or, if one believes that there might be adverse personal consequences in doing so, simply foolish.
I do not subscribe to the latter. I believe the best way to fully understand and resolve the issues is to bring Continue reading