Although survey respondents agreed that regulatory considerations were the largest driver behind Anti-Money Laundering (AML) investment decisions, opinions on regulatory approach are marked by vast regional differences. This further emphasizes the challenges that financial institutions face in establishing a globally consistent approach.
Sixty-three percent of respondents said that regulators should provide additional guidance and 43 percent of respondents indicated that a stronger relationship with regulators would be a welcomed change in approach. Respondents in Western Europe and the Americas were the most interested in receiving regulatory guidance. In the 2011 survey only 14 percent of respondents wanted to receive more guidance, further emphasizing the acceleration of regulatory change and need for expectations to be clarified since the publication of the last survey.
Sixty-five percent of respondents stated that regulatory visits are AML personnel’s primary concern and 80 percent of respondents stated reaction to regulator demands is a primary reason for investment in a particular area of AML. It should be expected that regulator inspections will continue to focus on the key issues described above and that the number of respondents who have experienced a regulatory visit will continue to increase. The latest set of Financial Action Task Force (FATF) recommendations require member governments to complete a National Risk Assessment to identify, assess and mitigate their money laundering and terrorist financing risks. These assessments, once completed, are likely to influence the areas which each of the national regulators will focus on over the coming period. Regulators also continue to be cognizant of technological risks with alternative banking platforms, digital currencies and cybercrime highlighted as high risk areas.