Moody’s Talks: Risk Reframed

What’s wrong with AML?

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Jun 21, 2023
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INSIGHT

Humans vs. Corporations

  • Humans and corporations are distinct legal entities with different rights and liabilities.
  • This distinction poses challenges for KYC/AML compliance.
INSIGHT

Banks' AML Burden

  • Banks unfairly shoulder much of the blame for AML failures.
  • They must balance economic activity with risk management, facing constant pressure.
ANECDOTE

Multiple Regulatory Reviews

  • Carl Kemmerer's KYC/AML programs underwent multiple regulatory reviews annually.
  • This experience highlighted the need for clear processes and alignment between teams.
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