Fines, suspensions, and potential criminal charges for people involved in compliance violations are on the rise. The days of FIs navigating compliance problems by only paying huge fines and agreeing to an independent monitor are gone. The deterrent value of those penalties alone has run its course. Holding people accountable is now an integral part of any significant money laundering or terrorist financing probe.
If your livelihood and reputation are on the line, you should have every tool at your disposal to prevent, resolve, and manage financial crimes risks. Any investigator worth their salt will tell you that gathering as much information as possible is the only way to understand and report complex financial frauds. As such, you should be demanding resources, including more people and software, that can help scale communication and data sharing with counter-parties. Do you want to be the type of analyst or supervisor that when asked by a regulator or prosecutor if you sent a USA PATRIOT Act 314(b) request says “no.”
The bottom line is that failure to request information from a counterparty and proactively following-up in potentially critical situations is reckless for any AML professional. The people that will be held accountable in this new era are ones that allow cursory investigations and effectively turn a blind eye toward illicit financial activity.
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