“Operationalizing the provisions of the Bank Secrecy Act and USA PATRIOT Act has been and continues to be a complex endeavor. From the policies, procedures, and practices for know your customer or enhanced due diligence; to the systems and tools to monitor transactions and conduct surveillance of high-risk customers or classes of customers; to the ability to analyze, investigate, and report suspicious activity; and to trending, training and testing for and of those programs, the tasks of individual financial institutions are daunting. As daunting is the task of the regulatory community to set standards for and examine those programs. Continued cooperation and dialogue between the regulatory community and the institutions it regulates is critical to understanding and controlling the unique risks posed by money laundering and terrorist financing.”
This is an excerpt from Congressional testimony of Jim Richards almost fourteen years ago, yet it remains true today.
See attached testimony of James R. Richards on behalf of Bank of America before the House Financial Services Subcommittee on Oversight and Investigations on “Improving Financial Oversight: A Private Sector View of Anti-Money Laundering Efforts”, May 18, 2004