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Government watch
Compliance Alliance
Neopay is seeing similar demand. “It has become quite common for us to help the program managers develop their compliance frame- work and controls to meet the standard of their issuers ... and provide ongoing support to ensure they can effectively meet their ongoing obligations,” James notes. In many cases, program managers even are expected to bring com- pliance solutions to the issuers, rather than the other way around,” he adds.
An Ongoing Responsibility
Once a compliance program is written and put into place, it’s tempting to think the hard work
is done. But, in truth, it’s only just begun. “We find that many busi- nesses don’t consider their ongo- ing obligations,” James observes. “The expectation is sometimes that once a policy has been written or a third-party supplier agreement
is in place, you’re all set. But compliance is not a tick-box exercise.” Regulators expect an ongoing compliance strategy, in which companies constantly are monitoring their compliance obligations, training staff, testing their procedures and implementing improvements when necessary.
The NBPCA guidance calls inde- pendent testing “an essential step” in evaluating the effectiveness of compliance programs and recom- mends such audits be conducted at least every 12 to18 months. Testing should include reviews
of the company’s risk profile,
staff training, suspicious activity
Complier Beware
when it comes to aml compliance, there are plenty of must-dos. But there are also some key “don’ts.” we canvassed compliance specialists about the most common pitfalls that can hinder a prepaid provider’s aml efforts. Here’s what they said:
• Don’t compromise compliance in favor of financial interests. Spending money on compliance efforts may lower short-term profits—but investing in com- pliance will pay off in the long run—especially with regulators stepping up AML enforcement.
• Don’t let information silos develop. Ensure that there’s an ongoing dialogue and shar- ing of information between
monitoring systems and efforts to improve deficiencies noted in previous audits, the NBPCA notes. Independent audits are a great way to kick the tires of a compliance program to make sure it’s up to snuff before regulators come looking, adds Corbine, whose
firm provides BSA/AML audits.
With companies realizing the im- portance of ongoing, deep-rooted
compliance staff and the rest
of the organization, as many different departments may have information that is important to combatting money laundering.
• Don’t get comfortable. Criminals’ tactics are always evolving, so it’s vital to install a dynamic AML program
and regularly test procedures and make improvements when necessary.
compliance programs, support firms now are viewed as essential partners for many payments pro- viders. “We tend to have longer- term, ongoing engagements these days, and we are engaged far earlier within the development
of the client’s business than we used to be,” says James. “We’ve become an ongoing and funda- mental part of our partners’ compliance strategy.”