BY SARAH BETH FELIX, Special Correspondent
AS 2024 draws to a close, I figured I would summarize 2024’s AML consent orders and Civil Monetary Penalties (CMPs) into a “Top 10 what to dos” list to stay out of the weekly news.
1) From the AMLO to the analysts – think like a criminal. How will this customer/fintech/fintech’s customer/respondent bank/respondent bank’s customer exploit my rails? This mindset informs all controls.