Behavioural Change

Jo Geraghty


Embedding an effective AML regime

Date added: 25th Jul 2013
Category: Behavioural Change

The Financial Conduct Authority has released a report into Anti Money Laundering (AML).  Part of the report lists risk areas which are of current concern to the FCA.  These include direct risks such as E-money issuers and cybercrime and indirect risks such as digital currencies and alternative banking platforms.

AML is obviously an area which the FCA intends to take seriously and the report lists four banks which have been fined for breaches of AML regulations in the past two years as well as stating that a further three banks are under investigation.  Two reviews carried out by the FCA have identified high levels of potential AML breaches with a recent review into trade finance revealing that “about half of the banks had no clear policy or procedures document for dealing with tradebased money laundering risks.”

The report highlights the importance of firms being vigilant in all areas and suggests some measures which firms may wish to take to improve AML compliance including setting remedial plans and using a skilled person to test systems and controls.  But the FCA also highlights the way in which AML measures are the responsibility of senior management, with the report concluding:

“It is also essential that senior management set the right tone from the top. Without the right culture in a firm, it is unlikely that it will be able to embed an effective AML regime.”

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