Prior to September 11th and the USA PATRIOT Act, financial institutions had a similar outlook and level of investment into their anti-money laundering efforts. "The systemic 'wall' to stop money launderers was generally at the same height," says Moss.
Differences in the size of that wall are beginning to emerge. "Over the last three years, firms have been making decisions that have essentially changed that landscape," notes Moss. "The firms that invest more into a serious culture of awareness, serious technology, serious training, and take this problem seriously, will drive money launderers or fraudsters or employees looking to do malfeasant actions to other institutions."
The feds are coming to an institution near you, and they will most likely be the neighborhood or community regional bank. These unfortunately are the institutions that the OCC and other US federal regulators are concerned about. Their programs are going to be tested for CIP (Customer ID Programs) compliance and other BSA/AML/OFAC related issues.
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