Check-the-box issue validation is no longer sufficient now that US regulators have intensified their focus on remediation related to Bank Secrecy Act/Anti Money Laundering (BSA/AML) and sanctions compliance programs.
New enforcement actions against financial institutions are now routine, with regulators increasingly requiring an independent and objective validation program to assess closure of management action plans before closure packages can be formally submitted to the regulators.
Even if not specifically stipulated by the regulators, a robust issue validation program has become a fundamental expectation of regulatory authorities.
“In the past two years, more than 80 consent orders totaling in excess of $3 billion in fines have been issued by US regulators on financial institutions over BSA/AML and sanctions.”
There are five key benefits to introducing a robust and rigorous issue validation program:
Partner, Internal Audit, Compliance & Risk Management Solutions, PwC US
Advisory, Financial, PwC US