The bad guys read the regulations too. They seek out loopholes and weaknesses. When they find one, they exploit it. For this reason, we are constantly reviewing our risk assessments and procedures.

During an audit, or worse, a court case, you do not want to be presented with a policy document from your own firm dated ten years ago, with no evidence that it has ever been looked at since.

Tipping off understandably alarms frontline staff. If you’re not careful, you end up with a team terrified to talk to customers. Create sensible guidance for them.

More acronyms. Now that you have PEP - it is time to meet your new friend SAR. SAR stands for Suspicious Activity Report. From the

It's not an only-child. there's big sister Enhanced Due Diligence (EDD) and baby brother Simplified Due Diligence (SDD) too. We'll get to them later.