Ambition
Someone who decides must both know and want to
Management's headache
The starting point for every company management is, of course, to live up to laws and regulations and to do good business at the same time.
Unfortunately, a conflict of goals can be experienced when regulations must be complied with. The management's true ambitions and insights will inevitably become visible here. Many companies may be tempted to do the minimum possible, patch and fix or just hope for weak supervision. Others may end up in the hands of advisors who aim for perfection, far beyond reasonable realism.
Company management must have sufficient insight. Not only about unpleasant consequences of non-compliance but also about what needs to be achieved for AML compliance.
Policies must reflect ambition and link to real-world instructions.
Our experiences
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Risk-based approach in AML context does not mean to hope that the company goes under the radar.
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"I had no idea...." doesn't work. Anyone who is ignorant will not escape liability under the law
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Comprehensive anti-money laundering measures will never be effective unless management asks for results. Instead, they risk becoming a black hole that swallows resources, without the company becoming "compliant"
We are happy to start right away with...
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Quickly overview the current situation in the company, taking into account how AML is handled. We point out good examples and weak points in a scorecard.
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With this support, we talk with the management about urgent measures and ambition levels in the long term. A strategy may need to be formulated and decided upon.
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We then carry out a joint review of policies to ensure that they reflect current ambition and strategy
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