http://www.theiia.org/intAuditor/feature-articles/2012/august/effective-aml-compliance/ Blogen-us Thu, 11 Oct 2012 08:44:19 AMThu, 11 Oct 2012 08:44:19 AM http://www.theiia.org/intAuditor/feature-articles/2012/august/effective-aml-compliance/2012-09-06Our experience in gaming has been that irrespective of how hard one works to preempt regulatory findings both from the Compliance Staff and Internal Audit perspectives, they will "create" regulatory findings. IN one instance, a finding was generated despite a specific exclusion in the law based on a weak argument. However, I've come not to expect the Federal Government to play by the same rules as industry. http://www.theiia.org/intAuditor/feature-articles/2012/august/effective-aml-compliance/2012-08-10Please clarify the statement about the annual review requirement. It seems that the only explicit frequency requirement is from FINRA for brokers/dealers. According to the Federal Financial Institutions Examination Council BSA/AML InfoBase, there is no specifically frequency defined in any other statute, though the best practice is 12 to 18 month. http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_007.htm.