Given the high profile, that AML programs represent to the banks, what officer holds the responsibility ? Surely the CCO - Chief Compliance Officer has the obligation to ensure a program is in place which identifies potential laundering activities, with a high degree of certainty. What is unclear is who then holds the obligation to report, in what manner, and at what cost to the business ? This is a perfect area for independent consultants with a technology and financial transaction background to help implement, and deliver what the financial institutions need to keep compliant. Any chance to help out should be welcomed and this should be a growth area for years to come for the Big 4 auditing firms......Lets get to work and make the world a better place. Best Regards Mark CPA,PMP,CIA, CISA