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For high-risk customers, including PEPs, the bank should have gathered adequate information on the source of funds and wealth, assessed the money laundering risk of each customer, and ensured compliance and AML resources scaled with business growth to maintain effective systems and controls.

Effective AML/CFT policies, controls, and procedures must be risk-based, proportionate, and well-governed, as emphasized by FATF and national regulators. Proportionality ensures that controls are appropriate to the firm’s size, complexity, products, services, and risk exposure.

Senior management approval is essential to establish accountability and tone from the top. Regular review ensures policies remain effective as risks, regulations, and business models evolve.

AML responsibility is shared across the three lines of defense, not owned solely by the business. External validation may support assurance but does not replace internal accountability. While technology can enhance controls, regulators do not mandate the use of advanced or cutting-edge solutions; effectiveness and governance are more important than sophistication.

A risk appetite statement clearly defines the level and type of financial crime risk a financial institution is willing to accept in pursuit of its objectives. It guides decision-making and ensures consistency in risk-taking across the organization.