A TIP OF THE COMPLIANCE HAT TO CHRIS WORLEY AT UNIT 21 FOR HIS OBSERVATION THAT COMBINING AML AND FRAUD UNITS NOT ONLY WORKS, BUT IS A WAY TO RAISE COMPLIANCE EFFECRIVENESS

I must admit that I had reservations about the increasing compliance department administrative practice of bundling the AML/CFT and Fraud divisions at financial institutions. I was concerned that the consolidated team might not identify suspicious transactions in the field other than that of their original specialty., but with proper internal training, the result could be an improvement on effectiveness, with the added benefit of lowering the compliance budget at your bank, something we all seek to accomplish.

Furthermore, inasmuch as a number of money laundering operations are cleaning the proceeds of fraud crimes, having fraud specialists in the AML shop might better and faster identify suspicious transactions earlier on in the sequence of operations. Thanks Chris, you are right to bring up this added value, and to correctly point out its usefulness. Given the generally intimate relationship between fraud, and the necessary money laundering of the proceeds of that fraud, it's a smart move.