If there’s one thing our broad experience has taught us, it’s this: One size does not fit all.
Accounting Today
Accounting Today
Southeast’s fastest growing hubs as well as Bengaluru, India
In this replay of our recent webinar, our team explores the regulatory, operational, and technology developments shaping BSA/AML compliance programs today. The discussion highlights the importance of strengthening risk assessments, validating models, improving data quality, integrating fraud and AML functions, and maintaining documentation that can withstand examiner scrutiny.
Watch the webinar replay.
1. FinCEN's proposed rule shifts BSA/AML/CFT from a checklist-driven risk assessment to an effectiveness-driven program
The pending proposal moves the program away from procedural compliance toward demonstrating you're actually helping law enforcement combat illicit finance. The four pillars remain, but with greater emphasis on how they feed into your risk assessment. National AML priorities (including fraud) must now be embedded in your risk assessment with assigned risk grades and mapped controls. With a proposed 12-month implementation window, executives should direct BSA teams to analyze their risk assessment and controls, close gaps, and evaluate tech and AI resources now.
2. Corporate Transparency Act relief is real, but CDD obligations remain
As of the August 11 final rule, U.S. entity customers no longer report beneficial ownership information to FinCEN (only foreign entities/persons do), and previously submitted data will be deleted. However, this does not eliminate your 2016 Customer Due Diligence (CDD) Rule obligations. Institutions must still collect beneficial ownership at the initial account opening of a new customer. Verbal collection is permitted only for existing customers when your internal procedures require it, not for new customers.
3. BSA model validations are non-negotiable, even after guidance was rescinded
OCC, Federal Reserve Board, and FDIC rescinded prior Model Risk Management (MRM) guidance, but a footnote confirms supervisory action still applies if poor model management leads to violations. Best practice: validate at least every 3 years, and prioritize immediately if you've never validated, are switching models, or are deploying AI. With two-plus systems always in play, undetected data gaps (e.g., a transaction type not flowing into your monitoring model) can let suspicious activity slip through.
4. There’s no way to optimize bad data
Bad data in, bad data out. Before optimizing models, confirm transactions are coded correctly and customer data maps properly from the core. Signs that optimization and validation are overdue: high alert volumes that never escalate, rapid growth in customers or products, or new fintech or digital account delivery channels.
5. The dividing line between fraud and AML is disappearing
With fraud now a national priority and typologies evolving fast (e.g., check washing, synthetic identity theft, elder exploitation, account takeover, peer-to-peer scams), the separation between fraud and BSA/AML is dwindling. Executives should push for cohesive, cross-trained teams.
6. Documentation remains your strongest defense during examinations
Examiners want to see how your risk assessment, controls, Enhanced Due Diligence (EDD), investigations, and Suspicious Activity Reports (SARs) connect into a coherent program. Strong documentation demonstrates that risks were identified, assessed, monitored, and addressed appropriately.
Great leaders don't need to be the hero. They make sure their people feel seen, valued, and appreciated. In this Growth Spurt, Dr. Milt Lowder explores the power of giving credit, recognizing effort, and using words to build confidence. While compensation matters, meaningful recognition can be even more powerful in helping people feel that they belong, their work matters, and they're part of something greater than themselves.
GREENVILLE, South Carolina, September 1, 2026 — After 400 conversations exploring what helps people, teams, and organizations perform at their best, The Growth Project will mark the milestone with a special live event, “400 Conversations Later: What Great Cultures Have in Common,” on Thursday, September 10, at 10:30 a.m. EDT at Greenville One Center, 2 West Washington Street, Suite 200, in downtown Greenville.
Members of the media are invited to attend the live event, which will include the episode, a Q&A with the hosts, and a reception immediately following.
The 400th conversation represents the latest milestone for a podcast that has built a significant audience well beyond its Greenville-based beginnings. The Growth Project has recorded more than 350,000 total listens and downloads, reaches listeners in 113 countries, and has a 4.7-star rating on Apple Podcasts. Guests have included Kirby Smart, Dabo Swinney, Dan Lanning, Bonnie Bernstein, Spencer Strider, Ryan Holiday, and Bo Nix.
Created by AMPLOS, part of the Elliott Davis Human Capital practice, The Growth Project draws on the team's background in sport and performance psychology and is designed to challenge listeners to think differently about growth while providing practical tools to help people become the best version of themselves.
In March 2026, Elliott Davis announced a strategic partnership with AMPLOS to expand the firm’s Human Capital advisory capabilities in organizational behavior, team performance, and leadership effectiveness. The partnership was designed to complement the firm’s capabilities with expertise addressing the human and organizational dynamics that contribute to sustainable growth and performance.
“The AMPLOS team broadens the way we serve our customers,” said John Otten, Chief Executive Officer of Elliott Davis Advisory, LLC. “Their expertise in leadership, team performance, and organizational behavior strengthens our ability to address the human side of organizational success. The Growth Project extends that work by creating meaningful conversations about leadership, culture, and performance.”
The milestone episode, “What Great Cultures Have in Common,” will provide an opportunity to reflect on themes emerging from 400 conversations focused on growth and performance.
Dr. Drew Brannon, the Elliott Davis Human Capital practice leader, is a performance psychologist whose consulting work encompasses performance enhancement, leadership development, and culture assessment. He also serves as consulting sport psychologist to University of Georgia Football and has worked with executives and professionals across industries including healthcare, accounting, law, pharmaceutical, finance, medical device, and engineering.
“After 400 conversations, one of the most valuable opportunities is to step back and look for the patterns,” said Dr. Drew Brannon. “Great cultures aren't created by a single program or moment. They are shaped by how people lead, how teams work together, and the behaviors that are reinforced every day. This episode is an opportunity to explore what we've learned and give people practical ideas they can take back to their own organizations and teams.”
Following the live episode, attendees will have an opportunity to participate in a Q&A with the hosts. A reception will immediately follow.
Media Invitation: Local media are invited to attend and cover the live event.
What: The Growth Project: 400 Conversations Later: What Great Cultures Have in Common
When: Thursday, September 10 at 10:30 a.m. EDT
Where:Greenville One Center
2 West Washington Street, Suite 200
Greenville, SC 29601
Event Format: Live episode including audience Q&A. Reception immediately following.
Media Access: Members of the media are invited to attend the full program and reception.
Alice Grey Harrison
Elliott Davis
Alicegrey.Harrison@elliottdavis.com
864.477.9620
Advance media RSVPs are requested.
Elliott Davis Advisory, LLC is a U.S. top 50 accounting and advisory firm. With a team of more than 875 professionals across major U.S. markets and global alliance resources, the firm delivers tailored solutions to businesses, organizations, and individuals.
