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Senior management training, accountability and oversight for anti-money laundering compliance
Journal of Financial Compliance,
1
(1),
81-88
(2017)
Abstract
The aim of the paper is to communicate to AML compliance professionals about the importance of educating their boards of directors and/or institutional management teams so that they can create a culture of compliance that will permeate the organisation from the top down. The paper discusses how to accomplish this through appropriate approaches to training, what metrics to focus, how to establish accountability and things to consider in a compliance/risk assessment. There are few references in the paper due to much of it being based on the collective experience of the authors and how such items were handled in the organisation where both previously worked: both authors carry similar principles into their current organisations. The general format of the paper is that of a white paper, in that the authors are trying to persuade the audience to take a similar approach to what they have outlined.
Keywords: accountability; oversight; training; risk; metrics
The full article is available to subscribers to the journal.
Author's Biography
Zachary C. Miller CAMS-FCI is Vice President and Bank Secrecy Act Officer of Mid Penn Bank (Millersburg, PA), responsible for all aspects of the BSA/AML compliance programme including risk assessments, policy/procedure, managing the AML investigations, suspicious activity reporting, enhanced due diligence (EDD), currency transaction reporting, Office of Foreign Assets Control (OFAC) operations and AML business system areas which includes provision of oversight, direction and guidance to the BSA/AML team in the bank as well as interacting with law enforcement, and regulatory and audit personnel. Zachary is also responsible for the AML training efforts of the bank which he facilitates through various types of delivery methods so as to reach the entire organisation. A graduate of York College of Pennsylvania, Zachary has been involved in the AML field since 2009. Prior to his current role he has previously served as an AML analyst, quality control specialist and deputy AML officer at Metro Bank in Harrisburg, PA. During his tenure with Metro Bank, Zachary was part of a team that successfully remediated a regulatory consent order. Zachary obtained his CAMS designation in 2011 and the CAMS-FCI credential in 2014 as part of the inaugural class. In addition to working with ACAMS and other organisations as a speaker for several conferences and webinars Zachary also leads an independently organised AML peer group in central Pennsylvania which currently maintains nearly 75 members from various financial institutions and law enforcement agencies from the surrounding areas.
Lauren Kohr CAMS-FCI, CFIRS, has a background that includes more than 11 years of experience in the financial sector with significant experience in BSA/AML and OFAC compliance. Currently Lauren serves as the Senior Manager over governance, risk and quality control within the Financial Intelligence Unit at Pentagon Federal Credit Union, the third largest credit union in the USA. Lauren is responsible for several aspects of the BSA/AML compliance programme including risk assessments, policy/ procedures, governance, quality assurance and merger and acquisition due diligence. Prior to her current role she was the Director of AML/BSA/ OFAC Compliance at Metro Bank in Harrisburg, PA. During this time, she was responsible for developing, implementing and overseeing all aspects of the Bank Secrecy Act Compliance Program, including USA PATRIOT Act, Anti-Money Laundering and OFAC regulations. Lauren is continuously recognised as a central contributor within the financial industry for her strengths in BSA/AML compliance, governance, process improvement/implementation and quality assurance/audit reviews. Lauren was named the 2016 ACAMS Professional of the Year and authored the 2016 ACAMS paper of the year. She also currently sits on the Board of Directors for the US Capital ACAMS Chapter.
