In previous posts, we discussed the importance of correctly capturing Requirements (capitalized to indicate compliance requirements).   In conversations with large investment/asset managers (>$100bAUM) they have invested significant budgets in the on-boarding process. That process generally includes everything from KYC and AML to IMA/source documentation reviews.

In 2014, the United States’ regulatory hammer came down on BNP Paribas SA, sending a shock to compliance systems across the globe. Pleading guilty to violating the International Emergency Economic Powers Act and the Trading with the Enemy Act, the French bank would rack up a $9 billion price tag.[1] The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) would go on to make an example of those who violate sanction laws and risk national security interests, reaching the largest sanctions-related settlement of $963 million.[2]

Ah, Spring! The buds are showing on the trees and sunshine is breaking through the clouds. Here in New England, it’s the time of crocuses coming up through the soil, robins singing in the trees—and potholes forming on our streets and highways. They start out small and get progressively worse as we move into the next season, Road Construction and Detours.