Financial Crime World

Banks Make Progress in Remediating Internal Control Deficiencies

In a significant step towards strengthening internal controls, all 11 banks have made substantial progress in remediating deficiencies identified in their systems. The latest report highlights the improvements made in sanctions management processes, recordkeeping, and training programs.

Sanctions Management Processes

The banks have focused on improving sanctions management procedures by:

  • Strengthening and expanding existing processes
  • Automating procedures through system enhancements or new system procurement

Training Program

The banks have prioritized increasing competency and awareness among existing compliance and anti-money laundering (AML) staff by:

  • Widening the definition of personnel who require training
  • Requiring CAMS external certification for compliance officers at some banks
  • Implementing systematic training programs using external and internal resources to develop procedural, policy, systems, and overall compliance and AML competency

Independent Testing

Independent testing has seen significant improvement with:

  • Changed frequency and execution of testing accepted and actioned by most banks
  • Formal reporting of findings and automation of some reporting undertaken
  • Improved internal audit functions addressing deficiencies and allocating resources to independent testing

Remediation Aggregation

The remediation aggregation tables by categories and subcategories show a strong focus on improving internal controls across all banks. While there are still areas of attention, such as information sharing and record retention, significant progress has been made in remediating deficiencies.

Timeline of Remediation Actions

Most activities have been completed by the end of Q1 2017, with ongoing efforts expected to be completed by the end of Q4 2017. Remaining activities are planned for completion in 2018.

Overall, the report provides a positive assessment of the banks’ progress in remediating internal control deficiencies and highlights their commitment to strengthening internal controls and improving compliance.