Ravi Lahoti joins as our AML consulting partner. Learn more
We are proud to welcome Ravi Lahoti, former Principal Officer & Head of AML, HDFC Bank, as our consulting partner for AML. Check out more
Supervisory expectation has moved. The question is no longer whether an institution has a transaction monitoring system, but whether it can demonstrate that the system is effective. That demonstration needs evidence most banks cannot produce on demand: why a threshold sits where it sits, what the last rule change did to risk coverage, how a particular alert became a filing, and how long each step of that journey took.
“The question is no longer whether you have a system. It is whether you can show it works, and most banks discover the answer during an inspection rather than before one.”