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While banks routinely find fault with regulatory nuances, it is clear that in financial crime the disconnect between technical compliance and the real-world objective of preventing financial crime is profound. “The more time my team spend on EDD [enhanced due diligence], the more effective we are. And what stops us spending time doing EDD? Complying with regulations that have no effect whatsoever on financial crime. But if you do more EDD at the expense of your base level completeness, your regulator will whack you,” said one financial crime leader. “We spend so much of our effort and resources trying to do really basic KYC, keeping it constantly updated, for clients who, to be honest, won't really pose a real financial crime risk to us, in order to tick various regulatory boxes.”
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