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Enterprise AML Program Assessment

Enterprise AML Program Assessment. William Langford Director of Global Anti-Money Laundering JPMorgan Chase & Co. Identify Business Units. Assess Risks and Controls. Controls: Program Governance Business and Compliance Staffing Customer Identification and Verification

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Enterprise AML Program Assessment

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  1. Enterprise AML Program Assessment William Langford Director of Global Anti-Money Laundering JPMorgan Chase & Co.

  2. Identify Business Units

  3. Assess Risks and Controls • Controls: • Program Governance • Business and Compliance Staffing • Customer Identification and Verification • Customer Due Diligence • Transaction Monitoring • Currency Transaction Reporting • Suspicious Activity Reporting • Training • Compliance Testing • Independent Testing Risk Factors: Products and Services Offered High-Risk Customers High-Risk Geographies Business Strategy Use Metrics to Quantify!

  4. Establish Risk Definitions Assess Quantity of Risk Assess Quality of Risk Management Residual Risk

  5. Use Regulatory Resources • FFIEC BSA/AML Examination Manual – Appendix J • Comptroller’s Handbook – Large Bank Supervision • Document your standards W

  6. Review the Assessments • Ask questions: • Was the assessment completed according to established procedures? • Are risks sufficiently quantified? • Is the assessment of risks and controls consistent with audit and examination findings? • Document your review

  7. Compile the Results • Consolidate the results from each business unit into an easy-to-read (and interpret) enterprise-wide overview • Assess the results – where is your institution’s potential exposure? • Develop an executive summary that highlights and quantifies the most significant risks and the quality of risk management • Assess the direction the risk is trending and explain why

  8. Regulators BSA Officer Auditors Risk Assessment Results Senior/Exec Management Testing Units Risk Committees Communicate the Results

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