Page 44 - ACAMS-Today-V20N3

[ PRACTICAL SOLUTIONS ]
44 [ JUNE-AUGUST 2021 ]
How to add foundational value to your AML program
How does one measure value when value is different for everyone? Look at the non-fungible token, the digital work of art that sold for
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$69.3 million at Christie’s, or the Beanie Babies craze of the 1990s.
This applies to anti-money laundering (AML) programs as well. For example, the Office of the Comptroller of the Currency (OCC) has conducted horizontal peer financial institution (FI) examinations covering topics such as AML training and risk assessments. The OCC will provide a report to each FI included in the examination that includes leading and lagging practices, offering unique insight into what other FIs find valuable and allowing them to deploy these ideas and strengthen their own AML programs.
Keeping the OCC’s approach in mind, what constitutes value to an AML program cannot come from the perspective of one individual. In the spirit of collaboration, transparency, innovation and risk-based approaches――now codified in The Anti-Money Laundering Act of 2020 (AMLA)2――a number of forward-thinking AML professionals in different industries and FI asset sizes (most less than $50 billion) provided insights into three areas that have brought the most foundational value to their AML programs: AML risk assessment, staffing and training. These value-added practices can help FIs get ahead of the AMLA and the Financial Crimes Enforcement Network’s (FinCEN) advanced notice of proposed rulemaking (ANPRM) on AML program effectiveness, regulations, aid law enforcement and pave the path away from more technical “check-the-box” processes.