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In Low-Risk Assessments, Examiners and Compliance Officers Rarely See Eye-to-Eye

By Brian Monroe

In every longstanding relationship, there comes a point when both parties begin to question something they once thought they had agreed on. Talk to a Bank Secrecy Act officer at a conference, over dinner or in a bar and one point of friction with federal regulators inevitably becomes clear. "It doesn't feel like a risk-based system anymore," said an anti-money laundering (AML) compliance officer with regulatory experience, who believes that federal examiners have increasingly demanded that banks implement the same due diligence procedures for low-risk clients that they previously demanded only for medium- and high-risk clients. In interviews conducted for...

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