United States

Balancing AML programs with global competitiveness


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U.S. banks have eliminated existing and prospective foreign clients over the past several years as they sought to reduce money-laundering risk. Rather than simply rejecting foreign clients, however, banks can lay a foundation for doing overseas business by conducting a gap analysis.

A gap analysis compares the foreign bank’s AML practices with U.S. requirements. Combined with proper use of beneficial ownership information and updated monitoring systems, such an analysis can help banks expand overseas business while avoiding regulatory entanglements.

A gap analysis answers the following questions:

  • To what extent is the foreign bank’s AML program in line with U.S. expectations?
  • Does the foreign bank’s AML program comply with the home country’s own standards?
  • Does the bank’s AML program do what it was designed to do, based on a mini-audit of a sample of transactions?

By focusing on risk mitigation through an appropriate control framework, a gap analysis can document the steps a bank takes to improve its comfort level with a foreign client.

To learn more about mitigating AML risks through a gap analysis, download our white paper.


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