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.
AML officer has to ensure that management see the cost of the
program as essential to mitigate reputational and financial risk.
information can be used to cross sell other products.
staff should not have bonuses tied to the performance of business
staff can be close to the business, but must report outside to