During the past two decades, we have witnessed how financial crime compliance (FCC) has evolved from a basic customer identification program as laid down in Bank Secrecy Act 1970 to the current spectrum of regulations. And while technology can help address processes and platforms, one area may be overlooked in many institutions — people.
The regulations FIs must confront are vast and varied, including measures around corporate transparency and beneficial ownership, sanctions screening of customers and transactions, risk-based know-your-customer (KYC) and anti-money laundering (AML), politically exposed persons (PEP) and adverse media screening, anti-bribery and corruption — and so much more.
Financial institutions have been responding to these changing mandates by developing new and incremental technology platforms and processes. FCC rests on the three lines of defense — the operations team, the compliance function and the internal audit function. Across these functions, the three Ps play a crucial role in the success of compliance programs of any enterprise — people, process and platforms.
Many innovative solutions are being implemented to enhance effectiveness and efficiency in FCC, covering both processes and platforms. However, not much is discussed about change management focused on people,…
