AML Regulatory Trends in the United States
● Regulatory Overview: Brief History
- USA PATRIOT Act
- Early Enforcement Actions
● Regulatory Culture 2008
- Recent Enforcement Actions since August, 2007
- Lessons learned from Enforcement Actions
● Organizational Structures
- Historical ? separate functions
- Emergence of the Financial Intelligence Unit
● Suspicious Activity Reporting Process to FinCEN
- SAR Trends
- Usage
AML Compliance Practices in US Financial Institutions
● Current State
- Regulatory Emphasis
- Challenges
● Emerging Practices
- Customer Risk Scoring
- High Risk Monitoring
- Justification of Monitoring practices
- Post Analysis / Business Intelligence
● Regulatory Examination Process
● International Implications |
