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Common AML compliance failures
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Extraordinary AML compliance failures (intentional at the executive level)
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Widespread SOX failures (Sarbanes-Oxley Act) primarily control breakdowns leading to reconciliation breakdowns and incorrect reporting
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A broad failure of licensing controls where the company providing insurance products in the name of several major banks did not know which products were licensed is which states
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For each case we will look at:
- What was the cause of the compliance failure
- How was a problem identified (red-flags, check list items, audit steps) and
communicated internally (escalation process)
- What was done with regard to communication with regulatory authorities
- What did it take to investigate and address the failures
- What internal controls and risk mitigation steps were taken to prevent recurrence