Promote and demand a “culture of compliance” within your organization: It’s not just another AML concept or buzz term. Nay. Compliance should be a cultural ethic that permeates throughout your business. It begins and ends with the tone at the top. Set the standard for compliance in your office and lead by example. It’s not enough to have an AML program and the best of intentions. While this can certainly help, in order to be successful, compliance must be embedded in your workplace culture.
Almost a year ago, FinCEN issued an advisory about this very topic. In so doing, they sought to highlight the importance of a strong culture of BSA/AML compliance for senior management, leadership, and owners of all financial institutions subject to FinCEN’s regulations, regardless of size or industry sector.
FinCEN indicated that financial institutions can (read: “must”) strengthen their BSA/AML compliance culture by ensuring that:
•Compliance Should Not Be Compromised By Revenue Interests
•Information Should Be Shared Throughout the Organization
•Leadership Should Provide Adequate Human and Technological Resources
•The Program Should Be Effective and Tested By an Independent and Competent Party
•Leadership and Staff Should Understand How Their BSA Reports are Used
It should be noted that this August 2014 advisory, according to FinCEN, was prompted by civil and criminal enforcement actions which identified BSA/AML shortcomings.
