First, how did you do?
Before we discuss a plan for tomorrow, it is important to review and assess how we implemented and executed our business continuity plan during the COVID-19 pandemic.
- How specific was it for our Anti-Money Laundering (AML)/ Bank Secrecy Act (BSA) program?
- Did it include plans on how to maintain our AML compliance throughout a pandemic?
- Did we lose any permanent or temporary staff, including consultants, during the crisis?
- Did we have an increase or decrease in transaction monitoring alerts/cases?
- How did we manage Enhanced Due Diligence (EDD) on the Payroll Protection Program (PPP) loans?
- Has the pandemic created a backlog for you at any point – of alerts/cases or of AML projects?
- And most importantly, did our pandemic plan “pass the test”?
Second, are you ready?
In order to be ready for what’s to come after COVID-19, it is essential to begin planning now. After reviewing the facts and seeing firsthand how our pandemic plan performed, what do we need moving forward? Some financial institutions might be in a situation when they do re-open, they might not be able to pull 100% of their staff in, but rather in a phased approach. In high-risk areas, existing consultants or staff may not want to continue commuting if they can find work-from-home scenarios. In any of these situations, financial institutions may need to hire temporary resources.
We will cover all of these questions and many solutions available to these challenges in our four-part series on Looking Beyond COVID-19. We will release one article per week encompassing each phase of what did and didn’t go according to plan, and how to guide the future for success.
ARC Risk and Compliance can help you with any of these scenarios – whether it is permanent or temporary case analysts to help clear alerts/cases or get you back on track with the AML projects you may have placed on hold (such as AML Model Validation, AML Risk Assessment, Policy & Procedure Updates, AML Software Tuning, etc.). Don’t wait and start planning now while there is extra time. Contact us today to learn how we can help you.
