Laura H. Goldzung, CFE, CAMS is President and Founder of AML Audit Services, LLC, an anti‐money laundering and fraud boutique consultancy specializing in independent testing and compliance consulting services to financial and nonbank financial institutions. She has worked with institutions that have been referred to enforcement for BSA/AML violations, helping them to bring their AML programs into compliance.
“Is this us?” When it comes to penalty actions that include insufficient resources, that is one of the first questions the average AML compliance officer should ask after reading some of the more recent enforcement cases, like the one that resulted in an $8 million penalty for Raymond James, or the $16.5 million headache for Credit Suisse. […]
It’s that time of year, scheduling the independent review. You call your provider, discuss available dates for the onsite visit and request the proposal of a new provider or if your provider is returning, the engagement letter. The proposal or engagement letter will outline the who, why, what, when, and where, much like we see […]
