Home » The Saga of an AML Compliance Officer by Dennis M. Lormel
The Saga of an AML Compliance Officer Dennis M. Lormel

The Saga of an AML Compliance Officer

Dennis M. Lormel

Published
ISBN :
Kindle Edition
8 pages
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 About the Book 

This is the true and compelling real life story of a Bank Secrecy Act (BSA) and Bank Compliance Officer. She had been recently hired by a small community bank. Shortly into her tenure at the bank, she realized something was seriously wrong. TheMoreThis is the true and compelling real life story of a Bank Secrecy Act (BSA) and Bank Compliance Officer. She had been recently hired by a small community bank. Shortly into her tenure at the bank, she realized something was seriously wrong. The compliance officer determined that the bank was processing an inordinate and unreasonable amount of transactions per month- well in excess of what a bank that size should have been handling. She learned that the bank was dealing with third party processors and subsequently found out that the third party processors were transacting on behalf of internet poker companies. The compliance officer knew this activity was illegal. She went to the bank president and other executives to attempt to exit the business relationships and file suspicious activity reports (SARs). Although the compliance officer continuously attempted to do the right thing, she was constantly rebuffed or misled.What became apparent was that the tone at the top was not compliance friendly. Regardless of how dedicated and committed to doing the right thing a compliance professional is, if executive management does not adhere to a culture of compliance and exhibit the proper tone at the top, the compliance function is destined to fail. For approximately one year, the cultural conflict played out until state regulators closed the bank.During that year, as the gripping story unfolded, the compliance officer experienced many emotions ranging from stress and sleeplessness, to intimidation, guilt and fear for her safety. In addition, she incurred legal expenses to retain a lawyer. Despite her distress, she continued to try to do the right thing. As things progressed, the compliance officer cooperated with law enforcement and regulatory authorities.