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Money Laundering Bulletin

Self assurance

How do you demonstrate that your senior management are committed to AML? Denis O’Connor, managing director with the financial crime portfolio at the Association of Financial Markets in Europe has a strong personal view.

“Is AML discussed at high-level meetings; is the AML function adequately resourced; how much business is turned away?” A management not fully engaged is likely to be preoccupied with reputational rather than AML risk, O’Connor observed: “They’ll be looking at ‘will we get caught and what are the consequences if we are caught?’”

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