CP Currents Q2 The deadline has come and gone for financial institutions to be in compliance with USA PATRIOT Act Title III, Section 326 rules. However, many companies struggle to coordinate compliance programs that cover all divisions. Often divisions and far-flung office locations are not aware of company-wide compliance requirements and practices. Each division might be working with different software and procedures, resulting in duplicated efforts, redundant technology and wasted time and money. What’s the solution to this daunting challenge? According to Michelle Thiel, data and compliance manager for ChoicePoint’s Public Records Group, financial institutions are better off having all of their divisions on the same page. They should follow the same compliance procedures using integrated information systems. “Compliance is really everyone in an organization looking out for each other,” she noted. “It’s about everyone pitching in to improve processes, prevent risk and protect a company’s reputation as well as its customers and society as a whole. And, when compliance resources are coordinated, a company can save money.” Thiel said a coordinated compliance program begins at the top, with buy-in at the highest levels and the establishment of a core team to conduct a needs assessment. The team should be comprised of a compliance officer representing each department or division, such as audit, lending, deposits, insurance and more. As a starting point, the compliance team can inventory existing anti-fraud procedures throughout the organization. Many of these processes can be repackaged and integrated for PATRIOT Act compliance. Next, the team should compile a comprehensive set of policies and procedures, along with a plan of action. Having these written components is necessary for financial institutions to pass a federal audit. “At this point, regulators are looking for a documented plan and procedures that a company has begun,” said Thiel. “They know the tougher compliance pieces may take longer to implement.” It is recommended that institutions in industries other than the financial realm have a contracted or internal audit component to apply the same best practice. Along with written policies and procedures and an action plan, companies should incorporate a training component and a self-test of the program. Thiel suggests that the plan be accompanied by regular progress benchmarks to keep implementation on track and moving forward.