“We can’t let our guard down because the stakes are too high.”

This was the strong reminder from Thomas J. Curry, Office of the Comptroller of the Currency, during his day three keynote at ACAMS 2016. With the event wrapping-up today at the Aria Resort & Casino in Las Vegas, his speech acknowledged the challenging reality of the current financial landscape, but reassured attendees that they should be proactive in looking for best practices to inspire their own AML (anti-money laundering) strategies.

“Risk is rising and changing,” he noted, “Banks and other financial institutions, by statute, are at the forefront of safeguarding our financial system.”

As the administrator of the federal banking system in the U.S., Curry briefly mentioned the global web of threats – from money launderers, narco traffickers, hackers, and others – but stressed it should not dissuade financial institutions from fulfilling their primary function: meeting the needs of customers.

Curry warned that “de-risking,” or exiting relationships or closing the accounts of at-risk clients, may not be the best response for institutions. He admitted that while “risk re-evaluation” is a critical part of managing the AML landscape, pulling business out of an entire country or region can lead to even greater problems.

As Curry described, financial institutions risk taking away financial tools and services from regions in need of economic development, particularly “when they need service the most.”

To confront this, Curry reminded the audience that clear AML standards lead to strong systems which can help institutions manage risk. He also reaffirmed a need to spell-out standards for banks on KYC (know your customer) standards and facilitate closer discussions between regulators and banks, and freely admitted that some of the responsibility for that rests with him.

“It’s incumbent on [my office] and regulators to be clear.”
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