Throughout 2017 and the start of 2018, we’ve seen an increased focus on anti-money laundering (AML) by regulators, notes Debevoise partner and co-leader of the firm’s Banking Industry Group Matthew L. Biben in his recent article “Strengthening Your AML Compliance Program” for New York Law Journal.
“Given this increased focus, we wanted to provide specific suggestions to compliance officers, senior management teams and boards of directors for strengthening their financial institutions’ AML compliance programs,” Mr. Biben writes. The article offers readers seven practical recommendations for strengthening AML compliance:
1. Cut the flow of suspicious transactions.
2. Review institutional subpoena compliance processes.
3. Remember that subpoena compliance is not ‘cooperation.’
4. Continue to invest in your people.
5. Review Your AML governance and accountability guidelines.
6. Ensure your board is actively engaged.
7. Follow proposed changes to U.S. AML regulations.
Debevoise’s Financial Institutions Group provides top-quality advice and counseling on critical issues to financial institutions around the world. More information about the Group can be found here.
Strengthening Your AML Compliance Program
By Matthew L. Biben
March 27, 2018