It is well understood that money launderers use deceit or theft to capture the processes of financial entities for illicit purposes. As a result, your AML compliance program must implement internal control designs that increase the chances of preventing or detecting such activities.
Financial managers and auditors are familiar with the concept and implementation of internal controls. The difference is that controls as part of an AML compliance program will be focused on mitigating risks discovered in a money laundering risk assessment. Further, internal controls as part of an AML program must be designed to generate the mandated reports and other surveillance, reporting, and records retention required by the Banking Secrecy Act, FinCEN and the Office of Foreign Assets Control, among others. … Continue reading