BANKING — SOLUTION BRIEF
“The most critical factor to the success
of an AML program is a risk-based
•	 Growing regulatory expectations.
Evolving regulatory expectations
frequently exceed the actual
•	 Inadequate monitoring systems.
Current monitoring systems don’t
cover an institution’s unique risks and
fail to address vulnerabilities like
•	 Undetected high-risk relationships.
High-risk relationships are a mystery,
and existing systems fail to identify
and monitor them.
•	 Narrow view of risk. Current risk
indicators are based solely on recent
transactions and do not take historical
behaviors and expected activity into
* Nancy Feig, “Regulators Focused on Anti-Money
Laundering,” Bank Systems & Technology,
February 21, 2008
YOUR GOAL: Ensure that your AML efforts satisfy regulators
Prior to 9/11, few financial institutions had formal AML monitoring solutions. But
post-9/11 legislation, such as the USA PATRIOT Act and the European Union’s
Third Money Laundering Directive, have made AML monitoring solutions an industry
standard. In fact, AML programs are among the most scrutinized risk management
functions. Regardless of sector or size, all financial institutions are under constant and
ever-increasing pressure to meet growing regulatory expectations.
Major regulatory agencies joined forces to publish guidelines for implementing a
risk-based approach to monitoring for illicit activities such as money laundering and
terrorist financing. In response, financial institutions are performing thorough risk
assessments of customers, products, channels, geographies and intermediaries. But
static, black-box AML monitoring systems lack the solid internal controls and systems
necessary for identifying and reporting suspicious activity.
The challenge is how to implement a risk-based AML program that adequately
addresses your institution’s unique risks, effectively covers the new and emerging