Anti-money laundering (AML) and compliance programs are useless unless they are implemented and enforced properly which involves ensuring that all employees including the board of directors and upper management have the proper training and the resources necessary to understand their roles in helping their companies be compliant. The 2017 Global Anti-Money Laundering and Sanctions Compliance survey found that 20% of companies “do not provide AML and sanctions compliance training for their boards of directors or are unaware whether their boards are being briefed on AML and sanctions matters.”
Recently, there have been enforcement actions that held board members accountable for their institution’s lack of compliance. In order to ensure that the company’s compliance needs are met, all employees should be trained on a regular basis in order to be kept up to date with regulations, non-compliance fines and sanctions, and other general AML risks.
It is critical for senior management to not only make sure proper compliance programs are implemented but they should also set an example in ensuring that the culture of compliance flows throughout the entire company and that all employees understand the importance of AML compliance and the consequences for non-compliance such as hefty fines or even jail time. .
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