NEW FINCEN ADVISORY ON CULTURE OF COMPLIANCE

The Financial Crimes Enforcement Network (FinCEN) has issued an Advisory* captioned Advisory to US Financial Institutions on Promoting a Culture of Compliance. I recommend that you take a few minutes to review it, as it summarizes the agency's current guidelines on compliance programs.

Here are the principal points that the Advisory makes:

(1) Leadership should be engaged.
(2) Compliance should not be compromised by revenue interests.
(3) Information should be shared throughout the organization.
(4) Leadership should provide adequate human and technological resources.
(5) The program should be effective and tested by an independent and competent authority.
(6) Leadership and staff shall understand how their BSA Reports are used.

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*FIN-2014-A007