Compliance organizations face challenges on multiple fronts in their efforts to control anti-money laundering (AML) risk. The perpetrators of financial crimes continually seek new ways to circumvent the protections in place, putting the financial institution at reputational and financial risk. The regulators bring their broad exposure to the latest nefarious techniques to each examination in an attempt to expose any system related or procedural weaknesses. 
Let’s cover just some of the questions you might ask yourself from time to time either preemptively or to prepare for your annual exam.
- Do you have the documents defining what is needed for your business?
- Does it provide the technical definitions that are actionable, the vision of the target state, and can the technical team interpret what is needed?
- Do you know that your system is working correctly?
- Has a recent data feed, batch process, or other technical function not had errors? Were they corrected?
- Are you sure your settings, thresholds and cases are set correctly? How do they compare to that of your peers?
- Are you preparing for an implementation, conversion, or upgrade; and if so, does your organization have experience performing such a task?
- If you’re working with a vendor on an implementation, conversion, or upgrade, do they provide testing and validation within the context of your needs?
- How confident are you that your AML/OFAC parameters are not over or under tuned?
- Do you make a plan on how and what you will test?
- Do you need a schedule of when to test?
- Are the procedures up-to-date and being followed?
- If there have been any new products and services that the institution has adopted or have you merged or purchased another line of business, has your program been updated to account for those?
- Do you know what new trends or processes are the regulators focusing on this year?
- If you’ve recently been through a regulatory review or internal audit, what were the findings? Did they identify areas that need improvement or other recommendations? Are you required to present an action plan and timeline?
- Did you have an poor exit interview, or receive an MIA, MOU or C&D?
If the answer to any of these was “no” perhaps it’s time to consider an IVV (Independent Verification and “Validation”, a False Positive Reduction, an Annual Independent Review, or even a Regulatory Remediation service. We would be glad to discuss any of these with you, what your options are and a plan that works for you. Call us at (609) 730-4123 or email us!
