What Is Lack Of Senior Management Involvement Or Lack Of Senior Management?

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Below are the key issues and how they can be addressed:

 Lack of senior management involvement or lack of senior management (e.g. Board buy-in)

The issue arises from the limited senior management involvement and challenge in AML and ABC compliance activities. This involvement is essential, as senior management should set the “tone” for the success of overall compliance efforts and AML programs. Senior management need to take the lead on AML issues, for instance through communication with all levels and participation on everyday decision making processes. It is also important that the responsibilities of senior management are cleared defined and that there is a clear organisational structure to deal with and discuss bribery, corruption and …show more content…

This may have consequences for reporting and escalation of suspicious transactions and activities to the AML department. Senior AML management and the MLRO need to ensure that communication across the different functions of the business is effective in order to lead in the effort of combating money laundering and have an overall understanding of the client’s database. Senior AML management is also responsible for ensuring that staff is updated of any significant changes in the AML policies and procedures and their personal legal …show more content…

The regulatory framework has been tightened up by placing new requirements on banks and financial institutions. Large financial institutions have been fined increasingly by regulators due to failures in AML systems and controls and violations of sanction regimes which place AML divisions under great pressure as the expectation is to comply and have in place a good financial crime compliance programme. Senior AML management must produce a positive AML culture which will comply with the UK regulatory framework and will meet the regulatory

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