For money-laundering compliance officers, a classic Bob Dylan song offers a word of sound advice: “You better start swimming or you'll sink like a stone, for the times they are a-changin'.”
Money Laundering Compliance Examinations
The biggest change that financial institutions face is the new, expanded-scope anti-money laundering (AML) regulatory examination and the proliferation of Written Agreements, Memoranda of Understanding, or Cease and Desist Orders issued by bank regulatory agencies should the financial institution be found to be deficient. An analysis of recent regulatory orders including, among others, AmSouth, ABN AMRO, Standard Chartered, Hudson United Bank, and City National Bank, demonstrates that the regulators are focused on multiple issues.
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