In September 2015, ACAMS published a whitepaper titled “The Challenge of AML Model Validation,” to assist BSA/AML personnel with addressing the most common examination challenges regarding AML model validation. It’s now five years later, and many financial institutions continue to face significant challenges in ensuring their AML models meet the expectations of the regulators and their institution’s needs. Coupled with the negative global economic impact caused by COVID-19, it will be even more challenging for financial institutions to meet their obligations under the Bank Secrecy Act (BSA) and anti-money laundering (AML) regulations.