What an effective bank anti-money-laundering program must do

An anti-money-laundering program is a system for detecting and responding to financial-crime risk. A policy document alone does not demonstrate that the system works. Federal banking examiners assess the controls a bank actually operates, including how it identifies customers and reviews unusual transactions.

The core controls

The FFIEC examination manual identifies internal controls, independent testing, a responsible compliance officer and staff training as core program components. Customer identification and ongoing, risk-based customer due diligence support those controls. A bank should understand the purpose of a customer relationship and investigate activity that does not fit it.

What meaningful evidence looks like

Useful questions for an oversight committee include: Are alerts being resolved promptly? Can reviewers explain why an unusual transaction was escalated or closed? Did independent testing identify recurring failures? Who owns each corrective action, and what evidence shows it was completed?

Those questions distinguish an operating control from a promise to improve. They also make broad claims about a bank's compliance easier to evaluate.

Applying the lesson to Bancrédito

FinCEN's 2023 enforcement announcement identified weaknesses in suspicious-activity reporting and correspondent-account due diligence at Bancrédito. This explainer does not establish that the bank subsequently rebuilt its compliance program; that would require current, institution-specific evidence.

Follow one alert through the system

Consider an unusual payment that triggers a review. The useful record connects the customer information, the reason for the alert, the reviewer’s decision and any follow-up. Counting alerts without examining those steps says little about the quality of the control.

A JournoPulse blog post, prepared with AI assistance from the linked sources. Our methodology · Suggest a correction.