Nothing strikes fear into compliance teams like an AML/Sanctions identified remediation, they know the next 12 to 36 months will be fraught with anxiety and unforeseen challenges, these may include:
AML matters tend to put incredible strain on compliance teams and force the re-evaluation of the manner, method, technology and team that oversees the compliance program. Getting through these actions with a well-defined plan, identifying resources to oversee and implement the plan, and thoughtful communications with the Regulator can make all the difference in enabling organizational confidence of program success and articulating that the program can eventually revert back to “business as usual.”
None of these matters are simple to navigate, often necessitating significant program changes and hundreds or thousands of extra hours of work and hundreds of thousands or millions of dollars in costs. Things get complicated quickly, but keep the following in mind when responding to Regulatory action: