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.
