Marathon running race, people feet on city road
The annual New York City Marathon is just a little over two weeks away. If you’re planning on running in it, you hopefully began training many months ago. Unless you’ve got some superhuman characteristics, the average person can’t simply run a marathon on a whim, without any training.
However, if information comes to light that indicates your financial institution has some holes in its AML monitoring process and may have missed some suspicious transactions, you could suddenly be feeling like you have to run a spur-of-the-moment marathon: the dreaded look-back project.
Whether your institution finds the deficiency itself or your regulator does, what it typically means is that your financial institution must “look back” at all applicable transactions for a period of time to see what you missed. And when you finds something, you must file the missing currency transaction reports or suspicious activity reports. As regulatory enforcement actions continue to focus on AML, more and more financial institutions are facing the prospect of undertaking a look-back project, which can be very time consuming. If you find yourself in such a position, however, don’t despair. The good news is that it is possible to come out alive and well on the other side… Read the full article on