The document outlines 5 key lessons for effective anti-money laundering (AML). 1) AML should not be viewed as separate processes but as a holistic approach. 2) Effective training of all staff, not just a yearly online course, is essential for a full understanding of money laundering risks. 3) Suspicious activity reports are about asking common sense questions to identify suspicious behavior. 4) AML benefits all stakeholders, not just regulators, by reducing financial crime risks. 5) Regulators must ensure firms have properly trained and competent AML staff who can think critically about risks.

1. Five key AML
lessons

2. 1
Anti money laundering should not
be viewed as purely a process in
discrete elements.
Too many regulated firms treat
AML as a series of discrete process
driven silos.

3. In many large firms the AML
Compliance Team is too far removed
from the Client On Boarding Team,
who in turn are totally removed from
the review and monitoring teams and
the salesforce.

4. Too many Know Your Customer /
Customer Due Diligence roles in large
firms are undertaken by people who
are trained to process applications or
forms without seeing the big picture
or thinking critically.

5. 2
Effective training and education of all
staff involved in AML is essential.

6. Until the salesperson, the Client On-
boarding Officer and the AML
Compliance team all understand the
bigger picture in regards to money
laundering and terrorist financing,

7. short term commercial gain will
continue and may be prioritised
over meaningful Customer Due
Diligence and AML controls.

8. Delivery of a once a year computer
based training package will not
achieve this. Practical, scenario based
content is the key to success.

9. 3
Suspicious Activity Reports (SARs) are
all about asking the obvious and
common sense questions.

10. This message has still not got out
there to frontline staff in too many
firms.

11. Staff don’t see that it’s in their interest
to report suspicious activity. If they
fail to do so they may not have job or
a successful employer in the future.

12. Too many firms still treat SARs as a
numbers game and an issue to be
dealt with by the AML team rather
than sales people or client on
boarding staff.

13. 4
AML is not a process to keep
regulators happy. It is in the best
interests of everyone: sales
people, senior management, law
enforcement, and yes, society as a
whole.

14. 5
Regulators need to challenge AML
competency and training within
firms.

15. Until we have recognition that AML is
a profession requiring critical
thought, technical knowledge and
sound judgement, we will continue to
see significant failures in firms.

16. Find out more about
professional
qualifications and
training in AML,
governance, risk and
compliance and
financial crime
prevention at
www.int-comp.com