Under SMCR, AML is a shared responsibility

The regulatory and reputational costs of having facilitated money laundering are substantial – as the highly-publicised woes of Danske Bank currently demonstrate. Gone are the days when responsibility for preventing such failings could be merely pushed down to the MLRO or compliance team. With the SMCR poised for application across UK financial services, Michael Harris stresses that senior managers must instil AML knowledge and vigilance throughout their institution.

Michael Harris is director of Financial Crime Compliance with LexisNexis Risk Solutions (https://risk.lexisnexis.com/financial-services/financial-crime-compliance).

At its initial implementation in February 2016, the Senior Managers and Certification Regime sent shockwaves through the banking industry. While banks may have had plenty of warning of its implementation, when the deadline came, there was uncertainty as to how the legislation would really impact their day to day operations and decision-making processes.