Independent
Testing
Matters

A recent FINRA enforcement action resulting in a $20 million fine underscores the cost of persistent anti-money laundering (AML) failures. FINRA's use of "progressive discipline" in the case signals a diminishing tolerance for firms that fail to remediate known compliance gaps, particularly those involving foreign currency wires and customer due diligence (CDD).

The case is a reminder that AML programs must be tailored to a firm's specific business model. Unverified automated tools and outdated manual processes are no longer sufficient to meet regulatory expectations, and gaps left unaddressed after an initial finding carry escalating consequences.

Independent AML Testing at Diles Consulting

Diles Consulting's AML testing is conducted by former FINRA regulators with decades of direct experience scoping and completing anti-money related reviews. That regulatory background shapes how each engagement is approached: testing begins with understanding a firm's operations, risk profile, products, services, and customer base — not with a generic checklist.

This approach reflects client feedback describing Diles Consulting's recommendations as actionable steps that strengthen AML programs going forward, rather than a list of generic observations. By taking the time to understand how each client operates, Diles Consulting delivers testing and recommendations that are both practical and directly applicable to that firm's risk profile.

Services

Diles Consulting provides:
• Independent AML Testing
• Risk-Based Program Assessments
• Compliance Advisory Services
• Regulatory Readiness Support
• Policy and Procedure Reviews
• Training and Compliance Program Enhancement

Each engagement is designed to produce actionable recommendations that are clear, practical, and aligned with regulatory expectations, while accounting for the operational realities of the institution being tested.

A Long-Term Compliance Partner

Our clients return year after year, engaging our company as an ongoing compliance advisor rather than a one-time vendor. That continuity reflects Diles Consulting's focus on responsive communication and consistent, high-quality work product across engagements.

As AML regulatory expectations continue to evolve, firms need testing partners who understand both the examination landscape and the day-to-day realities of running a compliance program. Diles Consulting works with institutions to navigate that landscape through independent, risk-based AML testing tailored to each firm's business.

Waiting until an exam surfaces a deficiency is the costliest path, as this case makes clear. If your firm's AML program hasn't been independently tested recently or would benefit from a fresh set of eyes, now is the time. Contact us to get started.