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Pay Now or Pay Later: Anti-Money Laundering Programs Offer Road Map for US Funds Transfer Compliance

Published by: TowerGroup

Published: Jan. 17, 2005 - 6 Pages


Table of Contents


TowerGroup Take-Aways




Report Coverage




Requirements for Funds Transfers




A Continued Concentration on Controls




Cease and Desist


Exhibit 1: Three High-Profile Cease-and-Desist Actions in US Banks (2004)




Lessons Learned

Funds Transfer and Payments Clearing Have Special Requirements

Funds Transfer Programs Must Reflect the Risk and Complexity of the Business

Implement Controls or Have It Done for You

Actions Are Expensive

Willfulness Carries a Higher Cost

Automate and Implement Technology Solutions Appropriate to Your Risks

Regulators Are Under Pressure




Summary

Abstract

This TowerGroup ViewPoint looks at what has been required in several recent cases and offers a perspective on what other banks should take away from the actions, especially as regards funds transfers, bearing in mind that different regulatory agencies were involved in the various actions.

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