Individual AML compliance officers appear to be increasingly threatened with liability for failure to detect and prevent wrongdoing at their financial institutions. After setting out the key elements of the current regime of AML regulation, the authors describe the current trend as it has emerged in public statements from regulators, recent AML enforcement actions, and regulatory developments. They conclude with program suggestions to reduce risk for compliance professionals and their employers.
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Originally published by The Review of Securities & Commodities Regulation, December 2016
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