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Actual AML Rules Aside, US Banks Struggle with Federal Expectations

By Valentina Pasquali

Risk assessments, customer risk ratings and automated transaction monitoring. These are only a few components of a typical U.S. financial institution's anti-money laundering program not required by written law or regulation but still expected by federal examiners. Over the past 15 years, wide-ranging regulatory views have been promulgated by the U.S. Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corp. and the Financial Crimes Enforcement Network through guidance, supervisory letters, bulletins, alerts, advisories and the Bank Secrecy Act exam manual. While federal regulators are congressionally authorized to issue rules that implement the Bank Secrecy...

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