Most sanctions and penalties are levied not because a procedure is wrong, but because a firm does not follow its own procedure, or has no procedure at all.

The risk-based approach. In a nutshell, you must assess where your business is most at risk - in order to plan your mitigation. While some

While they’re far from perfect, following them, and the guidance that accompanies them, constitutes a defence in court. In short, The Regulations are our friend.

Why are we so seduced by acronyms? During presentations, I often start by describing the field of anti money laundering (AML) compliance as “alphabet soup”. “When in doubt, throw an acronym or two about.” It’s the consultant’s creed.

The very thought of a compliance framework can be enough to make a SME owner sigh. Regulations are written to cover all sizes of entities,