In recent years more firms have turned to managed compliance services because they can leverage compliance teams to quickly and efficiently implement and maintain a compliance program. The alternative of hiring an in-house full-time equivalent employee (FTE) may simply not make sense in the current regulatory and personnel environment. Many firms, paralysed by indecision, simply do nothing, which can lead to very bad regulatory, reputational, and business outcomes.

A reasonable AML compliance program must include an experienced money laundering reporting officer, include the involvement of senior management, have adequate systems in place and adopt customised policies and procedures, train staff, and maintain records.  

AML360's managed services incorporates each of these elements at a fraction of the cost to hiring a full-time equivalent professional. In doing so your AML compliance costs can be reduced from between 50% to 80%. Because we take advantage of regulatory technology, we also ensure you gain compliance efficiency.

Using a third party compliance firm to provide your compliance services, including utilising regulatory technology, offers many benefits over hiring one or more full time employees. AML360's managed services can implement a compliance program quickly and efficiently with an experienced team that applies an industry-wide perspective.  

Our team of compliance professionals have more regulatory knowledge than any one person a firm could hire.

When an issue arises, your firm can appeal to AML360's management for corrective action. Our firm, unlike a person, does not take vacation or sick days or ask for a promotion. Also, turnover among internal compliance officers has become an industry-wide problem. Faced with a limited career path, many compliance officers leave after a few years to make more money or to experience a different type of firm. In these circumstances you firm must go through the decision-making and hiring process all over again, creating business disruption. AML360's managed services eliminates all these issues.

AML360's managed services brings an independent perspective to the compliance function. Institutional clients and regulators value this independence and often give more weight and credibility to a compliance review prepared by an outside party rather than somebody reporting to senior management.

Conversely, an in-house AML compliance officer is inherently conflicted because he/she reports to senior management that may be the cause of the problem. In many cases, the AML Compliance Officer gets blamed because senior management views the compliance officer as the cause and not the solution. Unlike an outside firm which has many clients, an in-house AML compliance officer faces significant disruption if a compliance breakdown fractures the relationship with management.

What are the signs that a firm has done too little to implement an effective AML compliance program  They fail to spend enough on compliance. 

Firms also fool themselves into thinking they have done something significant. For example, they buy a compliance manual online or adopt policies and procedures but decline to implement their requirements. A do nothing firm ay inform an internal employee that he/she is now the AML Compliance Officer and allocate minimal resources to compliance. AML Supervisors often cite these practices in various enforcement actions as examples of failures to implement effective compliance programs.

Failing to implement a compliance program also will not work with institutional clients.

Once a firm makes it onto the regulator's bad actor list, expect to see them on a regular basis.