Background

In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, also known as the Bank Secrecy Act (BSA), establishing requirements for record keeping and reporting by private individuals, banks, and other financial institutions. In 1986 the Money Laundering (ML) Control Act added to the BSA directing banks and other financial institutions to establish and maintain procedures reasonably designed to ensure and monitor compliance regarding reporting and record keeping. Subsequent acts strengthened sanctions and established Suspicious Activity Report (SAR) requirements, and with the USA PATRIOT Act, criminalized the financing of terrorism, strengthened customer identification procedures; prohibited financial institutions from engaging in business with foreign shell banks; required financial institutions to have due diligence procedures and improved information sharing between financial institutions and the U.S. government.

Regulators expect financial institutions undertake a holistic, firm-wide approach to AML compliance risk management to encompass sound governance through: 1) AML policies, controls, and procedures; 2) Risk Assessments; 3) Transaction Monitoring Program; 4) Findings Remediation and Exception Tracking; 5) Investigations of Fraud and Suspicious Activity; 6) Training and Awareness; and 7) Regulatory and Compliance Reporting.

The inadequacy or absence of sound AML risk management exposes banks to serious risks, especially reputational, operational, and compliance risks.  Recent developments, including robust enforcement actions taken by regulators and the corresponding direct and indirect costs incurred by banks due to their lack of diligence in applying appropriate risk management policies, procedures and controls, have highlighted those risks. Much of these costs could have been avoided had the banks maintained effective risk-based AML policies and procedures.

Solution

Templar Shield’s Anti Money Laundering (AML) Solution, powered by the RSA Archer Integrated Risk Platform*, provides institutions with the ability to facilitate AML risk assessments, establish AML policies and procedures, create, track and justify AML rules and thresholds, manage quality assurance and threshold testing, facilitate fraud investigations and remediate findings with automated workflow, notifications, and interactive real-time reporting.

Key Features and Benefits:

  • Central Repository for BSA/AML Policies and Procedures, Risk Assessments, Transaction Rule Thresholds, Fraud Investigations, Testing/Optimization Activities, and Remediation
  • Reduced manual processes and ease of workflow and reporting
  • Establish, monitor, and optimize AML rules and thresholds to identify suspicious behavior
  • Integrate transaction monitoring systems with comprehensive compliance risk management
  • Report accurately and easily to regulators about AML activities.
  • Improved on-going monitoring and remediating based on risk prioritization
  • Holistic view of AML Management

*Note: Although built upon the RSA Archer Integrated Risk Management (IRM) platform, these processes may also be implemented on other integrated risk platforms.  Please see our services team for more information or to schedule a demo.

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