John Arvanitis, Managing Director in the Compliance Risk and Diligence practice, recently authored the article, “Beyond the Five Pillars: Taking a Holistic Approach to AML,” in ACAMS Today discussing the potential regulatory amendments to the Bank Secrecy Act. In the article, he presents a more holistic and continuous approach across the customer lifecycle to mitigate risk. The Financial Crimes Enforcement Network’s re-examination of the anti-money laundering (AML) requirements provides an opportunity to construct guidelines focused on AML risk across the entire customer lifecycle.
Traditionally, institutional AML programs have been based on the “five pillars”: internal policies, procedures and controls, designation of an AML officer, employee training, independent testing and customer due diligence. While this may seem like a comprehensive approach, this may not assess actual AML risks that exist within an institution. John suggests that taking a more holistic approach, like commonly used cybersecurity best practices to mitigate cybercrime, can have advantages over the compliance-base approach used in AML mitigation.
Read the full article here.
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Anti-Money Laundering
Kroll’s anti-money laundering (AML) solutions are designed to help minimize the risks associated with money laundering and other illicit activities and to ensure compliance through the development and management of ongoing compliance programs and processes.