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The Five Pillars of an Anti-Money Laundering (AML) Compliance Program

Is Your House Built To Withstand The Big Bad Wolf? 

Growing up, one of my favorite childhood stories was the fable about the three little pigs and how they went out into the world to build their homes and seek their fortunes. The first little pig was not too fond of hard work, and did not give a hay about the details because they liked to play all day, so they quickly built themselves a house of straw. 

The second little pig was building their house too. They did not like to work harder than any other pig, so they too built a quick and easy house of sticks and did not shop around for any bricks. 
The third little pig was a wise little pig. They were building a house too, but they were building theirs with bricks. They did not mind hard work; they wanted their house to be strong and solid as they knew that in their world lived a big bad wolf who liked nothing better than to catch little pigs and, well you know the rest… 

In the real world, particularly start-ups in the financial institution (FI) and financial technology (Fintech) sectors, building a solid and effective compliance foundation can make a world of difference between being successful and falling to the big bad wolf when they come around. 

One of the major compliance components of a successful FI or Fintech is to build a solid and effective Anti-Money Laundering (AML) program1, which should include complying with AML laws and regulations. Money laundering is the process of making illegally gained proceeds appear to be legal. In its mission to “safeguard the financial system from the abuses of financial crime, including terrorist financing, money laundering, and other illicit activity,” the Financial Crimes Enforcement Network (FinCEN) acts as the designated administrator of the Bank Secrecy Act (BSA) which is the primary AML law in the U.S. The BSA was established in 1970 and has been amended over the years to become one of the most important tools in the fight against money laundering. In 1986 the Money Laundering Control Act was established, and the Four …

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© Copyright 2023. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.


afc, anti-money laundering, anti-corruption, finance, financial services, article

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