Dear AML professionals
Another week has come to an end, bringing with it key developments and insights in the world of financial crime compliance.
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Let’s see this week’s AML highlights:
The Art of Compliance Is About People, Not Just Rules
In financial crime compliance, it’s easy to think our job is only about oversight - checking, monitoring, enforcing. But the real impact comes when we pair that oversight with support.
Compliance works best when people don’t just follow the rules because they have to, but because they understand them and feel part of the bigger responsibility.
That’s why how we engage with our teams matters. Do we leave them feeling policed, or do we give them the tools and confidence to do the right thing?
This week’s reminder: Stronger compliance grows when there is trust, guidance, and shared accountability.
Wishing you a week where rules and relationships work hand in hand.
Warm regards,
Anna
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Here are this week’s news:
FinCEN Advisory on Chinese Money Laundering Networks (CMLNs) and Cartel Connections
FinCEN has issued an advisory highlighting the role of Chinese Money Laundering Networks in supporting drug cartels. The advisory outlines how these networks use informal value transfer systems to launder proceeds from illegal drug sales. U.S. financial institutions are urged to update their AML programs to detect these typologies and report suspicious activities, signaling an increased regulatory focus on combatting sophisticated money laundering operations.
DeNederlandscheBank (DNB) fined bunq B.V for AML failures
De Nederlandsche Bank (DNB) imposed an administrative fine of €2.6 million on bunq B.V. for serious deficiencies in its anti-money laundering (AML) controls between January 2021 and May 2022. DNB found that bunq failed to adequately follow up on transaction monitoring alerts and irregularities in several high-risk customer files, leaving potential money laundering risks undetected or unreported. bunq has lodged an objection to the decision, which remains pending.
BaFin Orders Raisin Bank to Remedy AML Failures
BaFin, Germany’s financial regulator, has ordered Raisin Bank AG to remedy significant deficiencies in its anti-money laundering (AML) controls. The shortcomings identified included weaknesses in the bank’s risk analysis, customer risk assessment, IT-based monitoring systems, and the duties of its money laundering reporting officer (MLRO). These gaps were deemed to have a serious impact on the bank’s ability to prevent money laundering and terrorist financing.
FATF published several resources
On 28th August, the FATF released a series of new resources aimed at strengthening how countries and stakeholders assess money laundering risks. The publications include:
Money Laundering National Risk Assessment Toolkit – Annexes A–C
FATF launches National Risk Assessment toolkit to help countries identify greatest ML risks
Annex C: Package of NRA Tools (World Bank, IMF, Council of Europe)
Quick guide on assessing the ML risks of virtual assets (VA) and VASPs
Quick guide on assessing the ML risks of legal persons and arrangements
Quick guide on assessing the ML risks of the informal economy
In case you missed this week’s LinkedIn posts:
Monday 25th August: JP Morgan Suisse fined CHF 3 million in relation to the 1MDB scandal
Wednesday 27th August: “We went with a well-known RegTech vendor. It felt like the safe choice - or not?”
Thursday 28th August: A summary of the Wolfsberg Group Statement on Monitoring Suspicious Activity
Friday 29th August: Negative feedback can hurt - but in fact, it shouldn’t
Read our newly-published article at www.amlcube.com:
“What differentiates an average AML program from a Strong one?”
That’s all for this week. Feel free to contact us at info@amlcube.com and tell us what future subjects you would like us to cover in future editions.
And if you are wondering who we are, AML Cube and its associates can assist you re yourwith:
AML Compliance
Sanctions Compliance
MiCA Regulations
Cybersecurity / DORA Compliance
Visit www.amlcube.com to learn more about what we do.
Best regards,
Anna Stylianou