We have all seen the press releases; former FinCEN, OFAC, Treasury, DOJ and other senior government figures accepting well-paid positions, as global anti-money laundering heads at major US banks. where they oversee the entire AML/CFT efforts in those institutions. These are, by far, extremely qualified individuals, with extensive experience. The question remains, are they reforming American AML, now that they are in command ?
We still see obscenely deficient AML/CFT programmes, which receive repeated regulatory slaps on the wrists, and eventual sanctions, but since the compliance operations at many banks remain inefficient, unimaginative, and largely ineffective, the fines & penalties continue ad infinitum.
I would like to see these ex-government leaders, now sitting in their comfortable commanders' chairs, make meaningful reforms in-house, by creating new and effective compliance departments, through proper training, mentoring, conference attendance, and salaries commensurate with their assigned responsibilities. Money launderers are now operating at a level far above the knowledge base of the average compliance officer; Let's level the playing field, please, gentlemen. Upgrade compliance to a meaningful level.