Strengthen Financial Crime Compliance With Health Checks

Organizations can objectively and proactively assess their financial crime compliance program maturity by conducting a health check on their Bank Secrecy Act (BSA), anti-money laundering (AML), and Office of Foreign Assets Control (OFAC) controls. A health check evaluates the documentation and practices that form the compliance framework and reviews whether policies and procedures align with regulatory expectations and governance structures provide adequate oversight. By investing in such a review, organizations can reduce the risk of regulatory findings, improve efficiency, and position their compliance programs to support long-term growth.

The foundation of any strong financial crime compliance program is its alignment to regulatory guidance and expectations. All Federal Financial Institutions Examination Council (FFIEC) member agencies, including the Federal Reserve, the Federal Deposit Insurance Corp., and the Office of the Comptroller of the Currency, rely on the FFIEC BSA/AML Examination Manual to guide their exams. Falling short of its standards exposes organizations to regulatory findings, costly remediation, and reputational damage.

A health check helps organizations proactively identify weaknesses before regulators do. By mapping program elements directly to the manual’s guidance and current regulations, organizations can demonstrate preparedness and accountability. Importantly, as examiners increase their focus on emerging threats, such as AI-enabled fraud schemes, misuse of crypto and digital assets, and technology-driven money laundering, alignment also means confirming the program can address risks that might not yet be fully codified in regulations but are quickly rising on regulators’ radars.

Measuring financial crime compliance program maturity

Financial crime compliance is dynamic. What once was sufficient for organizations might no longer be adequate as risks, regulations, and business models evolve. A health check can provide an opportunity to evaluate maturity across several pillars.

• Governance and oversight. Are reporting lines and escalation processes strong enough to meet regulatory expectations for the organization’s risk profile?
• Policies and procedures. Do policies and procedures reflect current regulatory requirements and expectations, evolving risks, and alignment with the organization’s risk appetite?
• Customer due diligence. Are onboarding and ongoing monitoring processes able to identify high-risk customers, maintain beneficial ownership information completely and accurately, and keep pace with the organization’s evolving risk environment?
• Regulatory reporting. As the organization grows, are processes dynamic, sustainable, and able to deliver timely and accurate reporting to the Financial Crimes Enforcement Network, OFAC, and other regulatory bodies?
• Training and awareness. Is training frequent, role-specific, and designed to keep staff at all levels informed of evolving risks and regulatory expectations?
• Emerging risks. How effectively does the program identify, monitor, and mitigate growing financial crime threats such as AI-enabled fraud, crypto asset misuse, and other technology-driven vulnerabilities?

By evaluating each of these elements, an organization can measure maturity by compliance with regulations as well as its adaptability, scalability, and sustainability.

A cost-effective path to compliance readiness

For many organizations, the idea of reviewing their financial crime compliance programs can seem like a daunting task, especially when considering the expense of a full-scale program assessment. When an organization is not yet due for its required independent audit but still would like to assess the state of its program, a health check offers a more cost-effective alternative by providing meaningful insights into the strength of a compliance program without the same amount of time and resources required by larger reviews.

In addition, a health check provides a more economical way to strengthen compliance programs. By identifying and addressing weaknesses before regulators uncover them, organizations reduce the likelihood of penalties, expenses that come along with remediation efforts, and reputational damage – all of which can far exceed the cost of a proactive review. In this way, a health check balances regulatory risk management with practical cost control. It’s a smart investment for growing organizations.

What to expect

This targeted review gives organizations clarity on their compliance program and a road map for improvement. It offers a transparent view of strengths and gaps with actionable guidance, and it allows organizations to address issues on their own timelines, which reduces regulatory compliance risk and supports sustainable growth. A health check is designed to be flexible and tailored to the unique size, complexity, and risk profile of each organization. While the specific scope might vary, a health check typically includes the following key components.

• Program review and documentation assessment. The organization’s compliance framework, including policies, procedures, charters, and governance structures, is evaluated against regulatory expectations and leading industry practices. This assessment highlights areas of strength and identifies documentation gaps, inconsistencies, or outdated materials that might create vulnerabilities.
• Technology and data assessment. Given the critical role of technology in AML compliance, the health check includes a targeted review of the organization’s AML technology stack and supporting data. This assessment focuses on key systems, particularly transaction monitoring, to evaluate system design, data flows, and data quality, including completeness, accuracy, and coverage. It also considers system governance, integration, and ongoing tuning and validation practices to identify technology or data gaps that could increase compliance or operational risk.
• Stakeholder walkthroughs. Discussions take place with compliance personnel, senior management, and representatives from critical business units. These walkthroughs provide insight into how policies and procedures are applied in practice and help bridge the gap between written expectations and day-to-day operations. They also serve as an opportunity to surface cultural, resource, or communication challenges that might not be apparent in an organization’s documentation.
• Gap identification and risk analysis. By aligning documented policies with actual business practices and current regulatory requirements, the health check uncovers potential gaps or misalignments. Such gaps or misalignments might include areas in which regulatory obligations are not fully addressed, execution doesn’t align with expectations, or inefficiencies create unnecessary risk exposure. Identified gaps are analyzed for compliance risk and for operational impact.
• Prioritized recommendations and road map for improvement. The health check synthesizes findings into a set of practical, actionable recommendations. These recommendations, in turn, are prioritized based on criticality, with immediate focus placed on high-risk areas that could draw regulatory attention or hinder operational efficiency. Lower-priority items are also included to support long-term program strengthening and sustainable compliance maturity. The result is a clear road map that organizations can use to prepare for upcoming regulatory reviews or proactively enhance their compliance posture.

Beyond exams: Strategic uses for a health check

The value of a health check extends well beyond regulatory exam preparation. Organizations can benefit from this proactive review in various situations, including:

• Leadership transitions. When new BSA, AML, or OFAC officers or compliance executives take on their roles, a health check offers an objective assessment of the program. It identifies strengths, pinpoints weaknesses, and provides a clear path for prioritizing improvements. This assessment helps new leadership quickly gain a comprehensive understanding of the program’s current state and where to focus their efforts.
• Product innovation. Before launching new products or services, a health check allows for a thorough review of the program’s ability to address new risk exposures. Recommendations are prioritized to strengthen controls where they matter most ahead of new business activity.
• Organizational change. Whether through entering new markets, merging with another organization, or experiencing rapid growth in customer base, a health check validates that compliance capabilities are scaling in line with business expansion. This proactive review prevents growing pains from becoming regulatory vulnerabilities.
• Emerging threats. With the rise of AI-driven fraud, crypto asset-related schemes, and other technology-enabled risks, a health check helps evaluate whether existing controls are resilient against these evolving threats and if the compliance program can adapt to the next wave of financial crime challenges.

In each of these scenarios, a health check provides clarity, strengthens oversight, and helps keep the compliance program aligned with regulatory expectations and the organization’s long-term strategic direction.

Proactive financial crime compliance

Waiting to identify weaknesses is financially, operationally, and reputationally costly. A financial crime compliance program health check provides organizations a clear, proactive view of their compliance framework. Instead of overwhelming leadership with broad findings, a health check delivers focused, prioritized actions. It highlights where resources can have the greatest impact, connects compliance to business strategy and gives upper management and executives confidence that the program is built to grow alongside the organization.

Amid rising regulatory scrutiny and emerging risks, the question is not about whether organizations can afford a health check. Instead, it’s whether going without one puts them at risk.