Most regulated firms understand the importance of risk assessments. Business-Wide Risk Assessments (BWRAs) and Customer Risk Assessments (CRAs) are well-established parts of a firm’s financial crime framework, helping identify where risks exist and ensuring controls remain proportionate. Many firms consider their financial crime risk assessments robust, supported by documented processes, annual reviews and board [...]
Recent proposals and commentary from the Financial Crimes Enforcement Network (FinCEN) have highlighted several areas where firms are continuing to fall short of existing AML/CFT expectations. While many of the proposed regulatory changes are not expected to take effect until next year, the findings provide a useful indication of where regulators are already seeing [...]
AML fines often dominate headlines, with regulators across the globe issuing increasingly large penalties for failures in financial crime controls. But while these figures attract attention, they rarely tell the full story. In reality, AML failures have consequences beyond financial penalties. Firms often face operational disruption, heightened regulatory scrutiny, and lasting damage to reputation [...]
