"Culture of compliance," a subject addressed in a number of recent speeches by U.S. Treasury and Justice Department officials advising financial institutions on how to avoid enforcement action over Bank Secrecy Act compliance lapses, is no longer a vague concept. Treasury's Financial Crimes Enforcement Network (FinCEN) on Monday defined the concept comprehensively in a six-page advisory explicitly aimed at "senior management, leadership and owners" of all financial institutions subject to FinCEN's regulations. "These leaders are responsible for understanding an institution’s responsibilities regarding compliance with the BSA and creating a culture of compliance at that institution. The commitment of an organization's leaders should be visible within the organization, as such commitment influences the attitudes of others within the organization," the advisory states. It also states that any financial institution can strengthen its Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)
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