AML/CTF: How to Measure Senior Management’s Commitment

A review of the recent sanctions imposed on organizations reveals that regulators frequently condemn the lack of governance, oversight, involvement and accountability at the senior levels of organizations with respect to anti-money laundering controls and the financing of terrorist activities. These major deficiencies are believed to be the source of the majority of regulatory deficiencies […]

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A Helpful Guide to the Examination Process, Part 2

Last month we discussed the pre-examination period and the actual on-site examination from the perspective of both bankers and examiners. One of the key themes that emerged was the need for clear and open communications between all parties. This time, we’ll continue with a discussion of the post-examination process, some comments about Supervisory Enforcement Actions, […]

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A Helpful Guide to the Examination Process, Part 1

I think we would all agree that the examination process has evolved over the years. With the greater technology, sophistication, and complexity of our banks, what used to be an annual surprise examination has taken on more of a continuous process. Granted, there are still periods of more intense activity such as actual on-site work, but […]

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