However, with regulators openly intensifying their scrutiny across financial services and holding senior management personally to account for non-compliance, boards who no longer consider AML a priority would be well advised to think again.
If boards cannot give as much time to AML as they used to, what should they look at?
Senior management can use their extremely valuable time to focus on the areas of AML which really matter, such as:
- Signing off on higher risk relationships, whether it be taking on a new customer or maintaining an existing one. Defining what constitutes ‘higher risk’ is critical here.
- Investing in making AML systems and controls as good as they can be. With the massive investment of people and money into AML work, it is critical to assess whether this investment is achieving what it is expected to, and making enhancements where necessary.
- Engaging proactively and constructively with regulators, armed with the MI necessary to reassure regulators that they understand the key risks their business faces in AML and related matters.
