When Was The Last Time You Independently Tested Your AML Processes And Controls?

During a recent assessment the Canadian regulator, the office of the Superintendent of Financial Institutions, has reportedly identified deficiencies with a bank's regulatory compliance management programme. As well as the adverse publicity this has created, the bank is also likely to face a significant monetary penalty. Since the problems with its processes came to light the bank have commenced a series of changes designed to overhaul its controls. They have conducted an internal investigation and made a number of sweeping changes, which includes bringing in new technology and making changes to its AML personnel and leadership. However, could these deficiencies have been detected at an earlier stage?