Answer:
This is a very difficult position to be in (especially as a new employee). However, you may want to use this regulatory issue as an opportunity to build a BSA/AML committee within your bank. This committee should consist of senior level management who can review the severity of the situation and make a risk-based decision for the bank. Ideally, this committee will help you develop a plan that can be shared with your auditors when they ask how you are addressing the problem.
First published on BankersOnline.com 3/6/06