What are the roles of internal policies, procedures, training and communications in AML efforts?
Zeldin, Deloitte: Train early and often. You can never train enough in the area of money laundering. Training has to be built off of sound policies and procedures. Compliance needs to become part of the year-end evaluation for all employees. Meeting financial goals can’t be the only criterion by which people are evaluated; how well they execute their compliance responsibilities also must be included in the evaluation. Without a clear tone at the top that compliance really matters, banks will sooner than not find themselves on the wrong side of a regulatory examination. Moorman, SAS: Constant knowledge transfer at a financial institution is essential to prevent the obsolescence of that institution’s compliance standards, identify areas with a need for additional training, reinforce the truism that every individual plays a vital role in the mitigation of risk and lead to enhanced risk-assessment of customers. The policies implemented should facilitate the upward transmission of requests
