USAA CASE: LACK OF SYSTEM TUNING, HUMAN TRAINING LEADS TO CASCADE OF LOW GRADES, UNSUSTAINABLE SYSTEM ALERT BACKLOGS, MISSED DEADLINES LED TO $140 MILLION PENALTY

On 28 March, an article from ACFCS reported that a $140 million penalty levied by FinCEN and the Office of the Comptroller of the Currency for AML failings at USAA has a host of lessons for the compliance community, essentially being a roadmap to evade systems, technology and human training pitfalls.  It says that abank must never forget about the vital importance of training for analysts, case-crafters and decision-makers – training that goes beyond technical policies and teaches how to think and act like an experienced, effective investigator.

https://www.acfcs.org/acfcs-exclusive-contributor-report-lack-of-system-tuning-human-training-leads-to-cascade-of-low-grades-unsustainable-system-alert-backlogs-missed-deadlines-in-140-million-usaa-aml-penalty/

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section View all posts by raytodd2017