AML Compliance Must Go On
By Mandy Bain
AML Button
© santiago silver / Adobe Stock
Our lives have changed in ways we could never have fathomed. Social distancing and masks were things I would have never guessed would be part of my daily life. After all, how does a hugger survive having to stay six feet away when meeting a friend in the store or seeing an opportunity to brighten a friend’s day with a hug? Are you serious? I just met a new client and I cannot shake hands? How does an extrovert deal with this new world of personal compliance?
I strive to do the right thing every day, both personally and professionally. Almost a year ago we were all challenged with implementing new safety protocols in our everyday life. Doing my part to end the pandemic and keep my loved ones safe meant I had no choice but to comply with the new norms. As I left the house, I would tell myself, “Mandy, do not hug anyone, stay six feet apart, and wear your mask!” (Staying in and skipping a weekly burger-and-beer opportunity was another challenge all its own; however, I digress.) A year later, all these personal protections that I thought were going to be something I could never do have become part of my normal daily life. I am compliant!
Two friends with protective masks greet with waving to each other.
© eldarnurkovic / Adobe Stock
As I thought about ways to meet the challenges of compliance in my personal life, I was also thinking about how I could help my clients with their AML compliance. As you likely know, one of the major parts of an effective and compliant AML program is the independent audit. Audit? Audit while social distancing? Audit while wearing a mask? Most of our clients are, in some capacity, working remotely, as I am. How do we ensure our client’s AML program stays compliant while keeping everyone safe? As these challenging times leave no room for choice when it comes to virus prevention precautions, there is no choice but to continue to keep our AML programs strong. As the thought of a remote audit swirled in my head, it was accompanied by thoughts such as: How? There’s no way. We strive to work face to face with clients. Audits are all about observation and interaction.
One by one, I began to work through solutions to each of my doubts. With technology, flexibility, and a dash of patience I soon realized the idea of an all-remote audit was actually possible. Exciting? Yes! But I’ll admit I was a bit nervous, too. I knew the desk audit would flow normally, but I was concerned about the process part of the audit. I would miss meeting people, observing company processes, having conversations, and interacting all together in person. While I was thinking through my questions and ideas, the client and I worked through scheduling online meetings, documentation, and confidential information protections; the remote audit was coming together and it was exciting. My reservations subsided, my confidence in the process was building, and I was seeing the same in our client. Soon, a successful remote audit was completed. We were able to help our client meet an important AML regulatory requirement and help strengthen their overall AML compliance.
Not only did we find solutions to the challenges of auditing remotely, but we also found processes that worked better for our client. The most striking benefit of the remote audit was flexibility in scheduling. On-site audits often require an aggressive schedule to cover all that is necessary, whereas with the remote audit, the client was able to break this time up; we held online meetings for two weeks, but only half-day meetings. This flexible schedule allowed both of us time to review documentation and bring thoughts, questions, and concerns to our next meeting. The company’s subject-matter experts joined online meetings as needed according to the audit schedule.
As we continue to navigate living through the pandemic, my first hope is that you stay healthy and safe. There are plenty of stressors in our current environment, please do not let your AML compliance or independent audit add to your stress. I would be happy to help you work through your thoughts and ideas, while keeping your program compliant and strong! Be safe out there!
