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OCC Guidance on Consultant Selection Renews Focus on Personal, Financial Relationships

By Brian Monroe

Recent regulatory guidance on banks use of consultants for anti-money laundering remediation work places a renewed focus on the personal connections that can affect the independence of consultants, according to compliance professionals. The guidance states that a bank must detail "any business or personal relationship" between a consultant and its employees, board members or executive officers and disclose if the consultant has hired staff previously employed by the bank. Consultancy selection, direct and indirect conflicts of interest on the part of consultants and the need for transparent draft reports are among the concerns spelled out in the guidelines issued earlier...

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