Why audit won’t save your anti-money laundering (AML) program

In financial institutions across the United States, there’s a reflex that’s become almost ritual.

When a regulator walks in, or a board member asks whether the AML program is working, the answer is the same: “We just passed audit.” It’s delivered with confidence, sometimes even pride, as if the risk has been neutralized. But passing audit doesn’t mean your program is safe.

It doesn’t mean it’s effective. And in today’s threat landscape, it doesn’t mean much of anything at all.