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The "ticking the box" attitude in Anti-Money Laundering (AML) compliance:

  • npoumbourides
  • Apr 29, 2024
  • 1 min read

A very common practice of merely completing mandatory regulatory requirements without truly understanding or implementing the underlying principles, for example of risk based approach (RBA) or risk factors impact on risk assessment. Financial Institutions’ AML Compliance Function, instead of actively perform their main task of identify, manage and mitigate the risks the organization is exposed to, they approach AML compliance simply checking off boxes already predefined, without applying any judgmental decision process, in order to meet minimum standards without meaningful understanding or engagement.


This attitude can lead to several issues:


  1. Lack of Effectiveness: Simply fulfilling regulatory requirements without a genuine commitment to understanding the risks and implementing effective controls can render AML compliance measures ineffective in detecting and preventing financial crime,

  2. False Sense of Compliance: Adopting a "ticking the box" approach may create a false sense of compliance, leading the compliance managers or senior management to believe they are adequately addressing AML risks when, in reality, vulnerabilities remain unaddressed,

  3. Compliance staff burn-out or overwhelming: A “ticking the box” culture usually is driven from wrong managerial decisions and is leading to a junior or mid-level staff burn-out, associated with physically or emotional stress, the useless or emptiness feeling and final unnecessary mass resignations affecting the compliance function operations.        

Remedies: To combat the "ticking the box" attitude, organizations should prioritize a culture of compliance that emphasizes understanding from ALL the staff members of the purpose behind their mission and tasks as members of the AML compliance function. This entails investing in robust compliance awareness, providing ongoing training and education and fostering a culture of incentives and inclusion for the staff members.

 
 
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