Each quarter we conduct anonymous surveys of anti-money laundering (AML) compliance professionals to get an idea of where the industry stands on a number of topics. We want to know where they are focusing their efforts, what rates they are following, what rules and regulations govern their business, and more. To further discussion among the AML compliance community, we make the results available to you as soon as possible after the survey closes. We encourage you to participate and share this opportunity with your network. The more participants, the more meaningful the results. Below is a list of our surveys with links to download each report.
|4Q 2019|| |
Please log in or register to view.
|This survey was designed to help financial institutions ensure they are doing everything they can before examination time. We will ask questions to gauge what examiners have been focused on, what areas of financial institutions' problems are being met with the most scrutiny, and how many banks have received comments or actions in the last two and a half years.|
|3Q 2019||Revisiting Regulation 504|| |
Please log in or register to view.
|In 2017, the New York Department of Financial Services (DFS) issued their Part 504 requirement for New York state chartered or licensed financial institutions. Part 504 requires that these institutions must validate their transaction monitoring and sanctions filtering programs, include annual training, and certify to these programs annually. In this survey, we want to see how clients have addressed and implemented this rule since it has been adopted.|
|2Q 2019||Customer Risk Rating||Please log in or register to view.|
|This survey was designed to benefit AML professionals to have a better understanding of how their peers are managing the their customer's risk rating.This survey will discuss methodology, classification of risk levels, and modifications made to software.|
|1Q 2019||AML Staffing||Please log in or register to view.|
|Institutions of all sizes look to their peers to compare how they're staffed, to understand what the market requires of an AML compliance analyst, and their utilization rates. This survey is designed to provide a BSA/AML officer and management a snapshot of what that looks like and how other institutions are finding new talent.|
|4Q 2018||Banking Marijuana||Please log in or register to view.|
|The purpose of this survey is to determine the status of financial institutions doing business with Marijuana Related Businesses. The survey will gather information such as what types of institutions are; if they are, how are they managing the risk; the number of customers they have; which are not; why not; what are their concerns; and more.|
|3Q 2018||Compliance Monitoring||Please log in or register to view.|
|In this survey we will be asking questions regarding compliance monitoring; the ongoing verification and adherence to institutional policies, procedures, and processes. As we all know, the compliance department is a dynamic and sometimes volatile environment, filled with ever-changing regulations and responsibilities. It can be hard to get a feel for what's considered 'best practice' because it can change by the end of the week. The best way we've found to establish 'best practice' criteria is by polling our readership and forming a foundation of public opinion within the financial industry. This survey will touch upon various methods of compliance monitoring and how financial institutions handle that responsibility.|
|2Q 2018||FinCEN CDD Rule||Please log in or register to view.|
|In this survey, we will be exploring what institutions are doing to bring themselves up to speed to comply with this new rule. The rule’s 25 percent reporting threshold will now require FI's to collect information on beneficial owners, individuals who own more than 25 percent of the equity interests in a company, or a single individual who exercises control upon the opening of an account. This affects the customer onboarding process and even the way the front office operates. Our survey touches upon several of the concerns people have expressed regarding the new changes.|
|1Q 2018||CyberSecurity/Part 500||Please log in or register to view.|
In this survey we will be diving into what cybersecurity measures financial institutions have in place to prevent cyber attacks and customer information breaches. With the passing of Part 500 regulation, compliance departments across New York will have a greater responsibility in maintaining cybersecurity and preventing threats to valuable information. Given the increased cybersecurity responsibilities being handed to compliance departments, we believe this survey will be beneficial for both compliance and IT professionals.
With that in mind, this survey will have a deep focus on IT and the various aspects of its integration within financial institutions.
|4Q 2017||General State of the Industry Update||Please log in or register to view.|
There is a lot of gray area concerning what the best methods are to stay compliant with AML regulation. A lot of the time, financial institutions believe they are doing everything correctly until they conduct an examination and multiple issues are discovered by regulatory agencies. Sometimes an institution’s quality standard isn’t the same as the industry’s quality standard. How can you be sure you’re doing everything correctly before examination time? We hope this survey can answer that question, as well as get an inside look at what other financial institutions are doing to remediate these issues.
|3Q 2017||Model Validations II||Please log in or register to view.|
In order to properly estimate if your AML program is doing what's expected of it, a model validation is vital and a key aspect to staying compliant in a constantly evolving financial landscape. Being able to properly evaluate and decipher the different facets involved in an AML program will give AML professionals a better understanding of what's necessary to maintain a healthy, multi-dimensional program.
In 2015 we conducted a survey on whether or not financial institutions were conducting model validations and how that process was being carried out. As the industry continues to evolve, we wanted to see how it has expanded and compare the results. We hope this survey, when compared to our previous results, will help answer many of the questions financial professionals have regarding model validations, program maintenance, and their growing importance in the industry.
|2Q 2017||OFAC Sanctions Lists||Please log in or register to view.|
|The OFAC sanctions or Specially Designated Nationals (SDN) list is constantly updated, and seems to be in a continual flux. To quote the official treasury page: "The SDN list is frequently updated. There is no predetermined timetable, but rather names are added or removed as necessary and appropriate." It's difficult to maintain all of the possible gaps that form between a financial institutions (FIs) OFAC filtering tool, and the official OFAC SDN list. In order to see how most FIs handle this burden, we decided to conduct this survey.|
|1Q 2017||Customer Risk Assessments||Please log in or register to view.|
|Late last year we received a reader request to cover customer risk assessment methodology. We also feel that all other financial institutions will benefit from this survey and the knowledge of how the financial community handles their customer risk assessment methodology. This survey will help give a better understanding of how financial institution’s are developing their customer risk assessment methodology and how they’re utilizing it.|
|NYS DFS Rule 504||Please log in or register to view.|
|On June 30, 2016, the New York State Department of Financial Services (NYS DFS) issued Final Rule 504, “Banking division transaction monitoring and filtering program requirements and certifications.” The rule takes effect on January 1, 2017 with the first reporting date of April 15, 2018. Even with a lead-time of 15 months, the certification requirement has us thinking where do we stand today so we know what to prepare for. In this survey, we wanted to get a feel for how our clients are reacting to the new rule, and many want to know how their peers are handling the change as well.|
|CDD Refresh Rates||Please log in or register to view.|
|The purpose of this survey is to see how institutions are monitoring and reviewing customer information as part of their CDD program. There are some “industry standards”, and one ex-regulator’s take on refresh rates, which you can read about here, but we thought it best to hear directly from institutions on how they’re handling this.|
|BSA Software||Please log in or register to view.|
|The purpose of this survey is get an idea of the similarities and differences between financial institutions’ (FIs) BSA/transaction monitoring software. We asked what features are offered by their software, how much does it cost annually, how satisfied they are, how customizable their software is, whether it’s hosted or licensed, and much more.|
|Staffing||Please log in or register to view.|
|The purpose of this survey is to give Chief Compliance Officers, Senior BSA/AML, OFAC, and KYC officers and managers insight into salary, staffing and utilization rates as it relates specifically to the compliance case analysts they employ.|
|State of the Industry||Please log in or register to view.|
|This survey will gather specific data to give the risk and compliance community a better understanding about the status of the financial industry, specifically as it relates to their regulatory BSA/AML exam. Some questions will be what the topics focused on in the final report of their exam; what was identified as the most critical issue by the regulator; what team participated in correcting the issues found; if any MRA, MRIA, and C&D’s were received; and if so, how many of each; and more.|
|Medical Marijuana||Please log in or register to view.|
|The purpose of this survey is to determine the status of financial institutions doing business with medical marijuana related companies. The survey will gather information such as what types of institutions are; if they are, how are they managing the risk; the number of customers they have; which are not; why not; what are their concerns; and more.|
|False Positives||Please log in or register to view.|
|The purpose of this survey is to determine if institutions are conducting false positive management within their AML compliance program (i.e. BSA/transaction monitoring, OFAC/sanctions filtering, and FinCEN 314(a)).|
|Model Validations||Please log in or register to view.|
|The purpose of this survey is to determine the frequency at which institutions are conducting an Independent Verification and Validation (IVV), or model validation, which software programs are they focusing on, and the number of issues that were found because of a model validation.|
|Compliance Monitoring||Please log in or register to view.|
|The purpose of this survey is to determine what the industry knows about compliance monitoring, if they have an on-going program in place, and if not, what are they doing instead|