FinCEN, U.S. regulators, and The Wolfsberg Group all have made it clear that the effectiveness of an institution’s AML/FinCrime program is critical and will be the standard for AML examinations in the future. Their definition of effectiveness focuses on three components: compliance with regulations, provision of highly useful information to government authorities, and a risk-based and reasonably designed program.
- Wolfsberg Statement on Effectiveness 2019
- Wolfsberg Group Statement on Developing Effective AML/CTF Programme August 2020
- FinCEN Advanced Notice of Proposed Rulemaking in September 2020
- U.S. National AML/CFT Priorities June 2021
- U.S. Regulators’ Joint Statement on the AML/CFT National Priorities June 2021
- Wolfsberg Group Statement on Demonstrating Effectiveness 2021
- Wolfsberg Group Paper on Effectiveness through Collaboration 2022
- Wolfsberg Group Response to FinCEN RFI
The U.S. regulators’ joint statement specifically calls out the need for institutions to prepare for these future rules by considering how to incorporate U.S. National Priorities into risk-based AML programs. The statement notes that banks will be supervised and examined on this incorporation.
As the regulatory focus on effectiveness intensifies, financial institutions must prepare and take proactive steps to ensure their programs meet evolving expectations. But how can you evaluate whether your AML/FinCrime program is effective and consistent with regulatory expectations, and what changes are needed to get there?
The SymphonyAI Sensa-NetReveal AML/FinCrime Effectiveness Maturity Assessment will help you navigate the recent guidance and proposed rulemaking in a structured, practical manner and come away with clear opportunities to improve effectiveness and program outcomes.
The assessment will help your institution:
- Determine the effectiveness of your program and specific controls and whether that effectiveness is demonstrable to regulators
- Identify areas to reallocate and refocus resources and the resulting associated cost savings
- Evaluate current program efforts and the procedural and technological changes required to improve effectiveness
- Tell your unique success stories to help foster positive relationships with regulators
