A US 'Look Back' at 10 years

An anti-money laundering (AML) professional recently recounted a conversation with a banking client, who knew that filing of a US regulatory Cease and Desist (C&D) Order against his institution was imminent, writes Bill Goss of IPSA International. The bank officer said his institution would take necessary action to address the AML deficiencies but hoped, above all else, that the Order did not include a “Look Back”...

William Goss CAMS (+ 1 212 205 4184, wgoss@ ipsaintl.com) is Senior Director of AML Services for consulting and investigation firm IPSA International in New York. His Tips and Suggestions has been the number one search return for “SAR Writing” for the past several years.

The colloquialism, Look Back, has become a term of art in the regulatory world and it basically refers to the “looking back” at a bank’s past transactions, often from years earlier, with a fresh set of eyes to identify what the bank may have missed through inadequate procedures, process, or oversight when the activity occurred. At the approximate ten year anniversary of “Look Backs”, now seems an appropriate time to look more closely at something that causes this level of trepidation in a banking officer, and assess whether it has been an effective tool to combat money laundering.