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ARTICLE · 25 SEPTEMBER 2013

AML Framework A Steep Learning Curve For Companies

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Your company is probably spending too much time and money on anti-money laundering compliance – and it could still get fined by the regulator.

BermudaCorporate/Commercial Law

Your company is probably spending too much time and money on anti-money laundering (AML) compliance – and it could still get fined by the regulator.

Religious adherence to passport copies and utility bills are as antiquated as the Ford Model T. And like the Model T on a race course, an antiquated compliance programme will serve only to get outpaced by the modern financial criminal.

So, in addition to the regulator not approving of your company's out-of-date AML compliance programme, it will do very little to stop actual financial crime from polluting the company's book of business.

The AML regulatory framework undertook a radical paradigm shift in 2009 that resulted in a very different emphasis from the previous framework. The current emphasis, called the risk-based approach, is a steep learning curve from the days when the 'spirit of the law' and 'best practice' were the guiding principles for regulation.

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