AML Conversations
Program Rule Comment Letter, DOJ Compliance Guidelines, Corruption Update, & FBI Crime Data Explorer
Oct 4, 2024
John and Elliot dive into the latest commentary on compliance programs, emphasizing The Wolfsberg Group's recommendations to enhance financial crime oversight. They explore new DOJ guidelines for corporate compliance and a proposed anti-corruption bill in the Senate. The FBI’s Crime Data Explorer is highlighted as a crucial resource for understanding crime trends. The discussion also touches on cultural protection efforts and recent legislative moves against corruption and human trafficking, underlining the ongoing battle against crime and corruption.
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Quick takeaways
- The Wolfsberg Group advocates for a flexible, risk-based approach to AML compliance with a proposed two-year implementation period for financial institutions.
- The DOJ emphasizes the crucial role of senior management in corporate compliance, requiring boards to actively engage with compliance teams to bolster organizational integrity.
Deep dives
Cybersecurity Awareness Month and Regulatory Updates
October marks Cybersecurity Awareness Month, prompting discussions around regulations in the financial sector. The Wolfsburg Group submitted comments on the federal banking agencies’ proposed rulemaking for the Anti-Money Laundering (AML) program, highlighting the need for a flexible, risk-based approach. They suggested a two-year implementation period to allow financial institutions to update their compliance programs alongside necessary revisions to the FFIC exam manual. These recommendations aim to enhance oversight and ensure that compliance frameworks adapt effectively to emerging threats in financial crime.
