When attitudes get stuck in Park:
I just returned from 14 ACAMS AML and financial crime annual conference in Las Vegas, I am puzzled about how some seem to be stuck in their positions, despite reports that clearly show improvement and progress.
Maybe it's just a case of the proverbial "glass empty or half full."
No credit for progress?
My last message, "Is Anybody Listening?" Covered the recent decree of the Department of Justice (the "Notice of Yates") that threatened companies that do not offer individual criminals to obtain credit for cooperation.
At the conference, after hearing several senior government officials a clear commitment from the private sector to AML challenges, continues to frustrate that you can listen to some political leaders criticize without highlighting the documented success.
In addition, many must realize that you can always call to improve compliance while recognizing their own shortcomings, if you are regulation and law enforcement, legislative or political leaders /.
I have maintained all along that the AML community has two public and private sectors and that we are stronger when we work in partnership.
Issues from the conference
Our conference was the largest program of ML in history (I should know-so old that I went to, or created, most of them) and included a much broader AML professionals when this area was first developed category.
We had representatives, securities, money service businesses, and insurance industries games to go along with the traditional banking public. Therefore, money laundering remained a major growth area.
The questions, however, tend to be very similar:
• Find qualified personnel
• Get adequate resources
• Manage led the formation of an organization.
• Stay out of trouble
What people are thinking
Participants at the conference were many occasions expressed their opinions and we have also provided the results of previous surveys. Here are some of their responses:
• The products the most, says down. 86% said they received different addresses the same issue of bank examiners different regulators. When I asked this question and our regulatory panel result, the response was, in part, what the different regulators are looking for different things in the review of compliance.
I let others decide if this response is sufficient.
• Where does the money come from? On the controversial question: "When things go wrong Institution, and no systemic breakdown of AML Program, in its opinion, individual (s) who should be held responsible?" The public is 30% split-each drive:
• The Board of Directors
• The first line of defense
• The / BSA AML Management
From Risking. Returning to the infamous debate "risk" ask the audience, "In the last year, did you go to a group of clients, because":
• You were worried about whether it can manage potential risk presented by these clients, 41%
• You were worried about the revision of the regulation that comes from having those customers (even if you can manage risk) -59%.
Clear to me that we all have some work to do ...
Survey results
ACAMS also worked with LexisNexis Risk Solutions in what has become an annual survey and I just want some answers highlight the note. For example, the challenge remains to determine the risk through a "risk assessment" was covered. As one of our panelists highlighted at the conference, risk assessments are not really necessary, but neglect the use of a process of identifying risks at your own risk.
Respondents told us that 51% still using a spreadsheet or manual document for the risk assessment and takes an average of 10 weeks to complete a risk assessment. Not surprisingly, we also learned that the process of risk assessment is difficult because (Note :. The survey will be available for ACAMS members in late October) 'the clear / changing regulatory expectations. "
Either in fact or not, we should not formally address this concern?
• The survey also examined in the next issue of beneficial ownership (I cover when settlement is final) and 76% say actual information despite the absence of rule in his place and collect beneficiary identification.
* To finish with an average score of positive full or glass, ACAMS announced our own survey of compensation LMA 2014 and a clear result is professional encouraging AML, despite many challenges they are proud of their career and the work they do.
