• There is a hardening stance from AML supervisors – especially when the quantum of the breaches is large. They are moving from an educative to an enforcement approach to ensuring the industry meets its legal obligations.
• AML/CFT legislation is not new. There is an expectation that each reporting entity will know what its obligations are. Using the excuse of not knowing is not sufficient. Directors of businesses have a duty of care to ensure the business remains compliant with its legal obligations. It is time to start asking yourself “How do I know we are compliant?”
• Identity verification is vital as is establishing source of funds.
• Failure to quickly identify issues and put things right creates a hardening of supervisor attitudes. When you read the cases, you will see that many of the issues kept occurring for many years and internal compliance checks had not identified and internally remediated the issue. Some of the findings from the external AML audits had not been actioned. This becomes a governance issue resulting in the supervisors wanting to send clear messages to others – you must take AML/CFT obligations seriously.

For more information or assistance, contact the team at Strategi Compliance.