When leading a financial services entity, in particular
within the company service provision, one needs to be aware of the
consequences of business decisions that could undermine the
entity's business policies, systems and the overall compliance
culture. In this 5-part series of articles, I will analyse 5
business decisions, through the legislative references such
decisions could fall foul of, the impact on the organisation these
decisions could have, and attempt to suggest a course of
action.
Conducting appropriate CDD/KYC on clients
A strong and aggressive sales culture within a firm, possibly
enabled by a change in senior management or a recent takeover by an
international firm, may lead to an increased pressure for
Compliance to lower the bar, particularly in conducting
CDD/KYC.
