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Building a sustainable Anti-Money Laundering compliance program

How to craft a stable, ongoing approach to fighting bank financial crime.


To meet Anti-Money Laundering (AML) and Bank Secrecy Act (BSA) requirements, many banks pursued resource-intensive look-back or remediation efforts—efforts that frequently forced “business as usual” work into the back seat.

Many of these efforts are drawing to an end as Matters Requiring Immediate Attention (MRIAs) and Matters Requiring Attention (MRAs) are closed. But the issues of security, money laundering and fraud continue, and banks may want to take steps to keep on top of these concerns.

Our report highlights six areas that can form the nucleus of an effective, sustainable program for addressing AML and BSA requirements on an ongoing basis.


By mastering several key business functions, banks can help build a solid BSA/AML program, one modelled after industry-leading best practices. The work includes:

  • Organizing operations and compliance resources around a risk-based approach

  • Building an efficient operating model that supports day-to-day prevention and detection activities

  • Mitigating business operations risks by establishing internal controls

  • Establishing governance and change management to support oversight and control

  • Conducting independent testing and auditing to detect issues, and to identify catalysts for change

  • Leveraging training to strengthen organizational awareness of emerging AML trends

Financial institutions are encouraged to engage in continuous improvement to position themselves to meet emerging AML trends and challenges.

Look-back and remediation projects may be fading into the background, but BSA/AML regulation work can now pivot toward future orientation and continuous improvement. Banks can move on from stop-gap measures and corrections around fraud and financial crime, and drive toward proactive efforts to anticipate, manage and minimize fraud and financial crime.

Leveraging industry best practices to carve out key components of a solid BSA/AML plan can effectively guide banks into the future.


Mark Boyer
Managing Director, Finance & Risk Services

He leads the North America Fraud and Financial Crime Group, specializing in complex, large-scale finance and risk programs.

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Philippe Guiral
Senior Manager, Finance & Risk Services

He leads Accenture’s North America Financial Crime practice.

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Blair West
Manager, Finance & Risk Services

She is a member of Accenture’s North America Financial Crime group and specializes in building program governance structures, and defining and executing strategic plans to enhance operating models.

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