Monitorships, transaction lookbacks and KYC remediations are the equivalents of a regulatory vote of no confidence. They can be incredibly disruptive, painful and can cost millions of dollars to implement. They are extreme measures that are taken when regulators have seen no improvement in succeeding regulatory exams or sometimes happen without warning when a criminal investigation reveals how an institution was at the center of a large scale money laundering or dollar clearing criminal enterprise and their anti-money laundering or sanctions compliance program and the controls underlying them failed in spectacular fashion. These epic anti-money laundering failures lead regulators to conclude that the existing program was so ineffective it is highly likely that suspicious activity, possibly a great deal of suspicious activity, has been going on undetected and unreported for a period of years.
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