Whose fault?

Read through any AML enforcement notice against a financial institution, or indeed a designated non-financial business or profession (DNFBP), since inception of regulation in the area and the same basic failures recur - whether in customer due diligence (CDD); record-keeping; monitoring; reporting; training; resourcing; or management oversight, in the sense of turning a blind eye to regulatory obligations until the authorities insist on speaking to someone at the top.

Timon Molloy (timon.molloy@lloydslistintelligence.com), Editor

Read through any AML enforcement notice against a financial institution, or indeed a designated non-financial business or profession (DNFBP), since inception of regulation in the area and the same basic failures recur - whether in customer due diligence (CDD); record-keeping; monitoring; reporting; training; resourcing; or management oversight, in the sense of turning a blind eye to regulatory obligations until the authorities insist on speaking to someone at the top.