The Bank Secrecy Act requires financial institutions to
establish an anti-money laundering (AML) compliance program to
prevent and detect financial crime. Failure to institute an
effective program can subject an institution to significant
regulatory oversight and penalties. AML compliance missteps have
caught numerous banks in the United States and abroad flatfooted
with inadequate compliance programs, resulting in massive fines and
government scrutiny that distracts from core business missions.
Given the importance of AML compliance, financial institutions
are increasingly turning to outside experts and consultants to
assess the sufficiency of their AML programs. These ad hoc
"assisted self-assessments"— often called "gap
analyses"—are typically commissioned by chief compliance
officers, senior management, or boards of directors either
proactively or as a result of an unfavorable internal audit or exam
findings, which can give rise to a fear of future
