The Head of Compliance is responsible for overseeing and managing the AML compliance program of the organization. When an external auditor identifies a finding that indicates a failure to comply with a regulatory requirement, the Head of Compliance should take prompt and appropriate action to address the issue and prevent recurrence. The best course of action is to submit a corrective action plan with a target timeline to the auditor and the relevant regulator, demonstrating the organization’s commitment to remediate the finding and improve its AML compliance program. The corrective action plan should include the root cause analysis of the finding, the specific actions to be taken, the responsible parties, the expected outcomes, and the deadlines forcompletion. The Head of Compliance should also monitor the progress of the corrective action plan and report any updates or challenges to the auditor and the regulator.
[References: = Some of the references that support this answer are:, JPMorgan Chase & Co. Global Anti-Money Laundering Compliance Program, page 2: “The Firm’s Global Head of Financial Crimes Compliance is responsible for overseeing the implementation and effectiveness of the AML Program and reports to the Firm’s Chief Compliance Officer. … The Global Head of Financial Crimes Compliance is also responsible for ensuring that the Firm responds appropriately to any regulatory inquiries, examinations, or investigations relating to AML matters, and that any identified issues or deficiencies are promptly remediated.”, The Board’s Role in AML Compliance, Section “Board Oversight of AML Compliance Program”: “The board should also ensure that the institution has a process in place to identify, report and correct any compliance deficiencies or violations in a timely manner. This includes ensuring that the institution responds to any regulatory inquiries, examinations or enforcement actions, and implements any required corrective actions.”, AML Compliance Officer: the Role, Skills, and Responsibilities, Section “AML Compliance Officer Responsibilities”: “The AML Compliance Officer is also responsible for: … Reporting to the regulators and auditors on the AML compliance program and its effectiveness; … Developing and implementing corrective action plans for resolution of problematic issues, and providing general guidance on how to avoid or deal with similar situations in the future.”, , , ]
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