On 11th October, an Occasional paper from RUSI examines the effectiveness of the current AML model, with particular reference to the financial services sector, and makes 8 relevant recommendations to enhance the model’s future effectiveness.  One of the comments made is about the growing attempt to transform reactive financial crime ‘compliance’ cultures into proactive ‘risk management’.  It says that there are early indications that such efforts, combined with initiatives to increase organisational agility, deploy new technology and improve partnerships with other financial institutions and the public sector, are improving the efficiency of the current AML model.  This helps, it argues, counter the “fragmentation” – between countries, private and public sectors, and individual institutions – that leads to financial institutions having a narrow view of who their clients are, and what their behaviour might signify – making potential criminality harder to detect.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: