Horizon Fintex

Sep 25, 2020

5 min read

FinCEN Files highlight glaring issues with current AML system and AML compliance programs

Considerations for financial institutions looking to re-approach their AML compliance programs

Current AML compliance requirements

Currently, a financial institution’s compliance with the Bank Secrecy Act and other anti-money laundering requirements is reviewed under FINRA Rule 3310, which sets forth minimum standards for a firm’s written AML compliance program.

AML compliance red flags

Although billions are spent on compliance each year, documents in the FinCEN Files show compliance workers at major banks resorting to basic Google searches to attempt to learn who’s behind transfers involving hundreds of millions of dollars.

Where does AML compliance go from here

We believe that the findings from the FinCEN Files will create a massive response from regulators to update compliance requirements and for banks to bulk up their compliance programs.


The leaked SARs only make up less than 0.02% of the more than 12 million suspicious activity reports that financial institutions filed with FinCEN between 2011 and 2017.

Horizon’s AML compliance solution

Horizon’s AML screening technology, AMLCop, offers firms a turn-key AML compliance solution for firms to continually streamline the verification of user details against a proprietary database of global sanctions, Politically Exposed Persons (PEPs), and watchlists.

About Horizon

Horizon offers a suite of integrated securities software applications for compliant issuance through secondary trading of electronic securities. Truly a compliance-first business, our solutions combine Wall Street and Silicon Valley to power the next generation of exchanges and securities offerings in the U.S. and globally. Visit us at https://www.horizonfintex.com/.