Compliance Culture

  • Compliance should be everyone’s role, supported by top management. The board should approve the AML program, and are responsible for implementing any examiners or internal audit recommendations.

  • The AML officer has to ensure that management see the cost of the program as essential to mitigate reputational and financial risk.

  • CDD information can be used to cross sell other products.

  • Compliance staff should not have bonuses tied to the performance of business units.

  • Compliance staff can be close to the business, but must report outside to ensure independence.

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