Five key AML lessons

1Anti money laundering should not be viewed as purely a process in discrete elements.

Too many regulated firms treat AML as a series of discrete process driven silos. 

In many large firms the AML Compliance Team is too far removed from the Client On Boarding Team, who in turn are totally removed from the review and monitoring teams and the salesforce. 

Too many Know Your Customer / Customer Due Diligence roles in large firms are undertaken by people who are trained to process applications or forms without seeing the big picture or thinking critically.

2Effective training and education of all staff involved in AML is essential.

Until the salesperson, the Client On-boarding Officer and the AML Compliance team all understand the bigger picture in regards to money laundering and terrorist financing,

short term commercial gain will continue and may be prioritised over meaningful Customer Due Diligence and AML controls.

Delivery of a once a year computer based training package will not achieve this. Practical, scenario based content is the key to success.

3Suspicious Activity Reports (SARs) are all about asking the obvious and common sense questions.

This message has still not got out there to frontline staff in too many firms. 

Staff don’t see that it’s in their interest to report suspicious activity. If they fail to do so they may not have job or a successful employer in the future.

Too many firms still treat SARs as a numbers game and an issue to be dealt with by the AML team rather than sales people or client on boarding staff.

4AML is not a process to keep regulators happy. It is in the best interests of everyone: sales people, senior management, law enforcement, and yes, society as a whole. 

5Regulators need to challenge AML competency and training within firms.

Until we have recognition that AML is a profession requiring critical thought, technical knowledge and sound judgement, we will continue to see significant failures in firms.

Find out more about

professional qualifications and training in AML, governance, risk and compliance

and financial crime prevention

at www.int-comp.com