Last week, the US Department of Treasury published its 2020 Strategy document that "employs a whole-of-government approach to guide the public and private sectors in addressing 21st century illicit finance challenges." The report highlights the risk-based approach as central to the 2020 Strategy.
Westpac Bank in Australia is facing one of its gravest crises from systemic AML/CTF failures over a 5-year period that contravened the AML/CTF Act on over 23 million occasions.
The Legacy Approach
In last week's article, we discussed Rules Engines vs Machine Learning for AML/BSA/CFT compliance. In this article we differentiate legacy AML process from modern a Agile Compliance approach. The legacy AML process consists of on-boarding customers, transaction monitoring and reporting. These processes are hard-wired into the software by technology companies and have been used for years.