You have completed a risk assessment and written policies and procedures to mitigate and manage those risks. Now is the time to get into the specific nitty gritty.
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.