The notion that a risk based approach to Anti-Money Laundering (AML) has forced a reappraisal of strategy is a slightly ambiguous one in today's climate, particularly so given that large financial institutions have now been pursuing such an approach for quite some time. Indeed the current hype surrounding risk-based responses comes solely on the back of pronouncements by regulatory bodies in both the US and the UK advocating their implementation. For the financial institutions themselves the outlook is consistent regardless of the hype, an holistic, risk based approach to AML is the most effective and relevant response to the way in which the business operates, in addition to representing the best possible means by which to identify potential money laundering.
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