A recent article, by Pricewaterhouse Coopers*, entitled Avoiding the Drift: Optimizing and Maintaining AML Surveillance Programs, makes a convincing argument that American banks are displaying a gradual process of inadvertent noncompliance. It takes the position that AML systems need to be constantly monitored, updated, maintained and repaired.
A new term has apparently been coined: AML Drift, which occurs when inadequate attention and resources have been dedicated to maintaining and sustaining the core components of AML programs that may now have been in place for more than a decade, and cites the increasing number of regulatory fines and penalties over the last five years, as proof thereof.
I can follow the author's logic, but wonder if allowing compliance to deteriorate is really a cost-based conscious decision, rather than ordinary negligence, on the part of management of some financial institutions.
* Avoiding the Drift: Optimizing and Maintaining AML Surveillance programs