Fourthline in the Netherlands published a White Paper in October says that regulators across multiple jurisdictions have turned their attention to the KYC and CDD files of existing bank clients.  It says that common mistakes banks make when initiating a remediation project include putting the burden on clients, recruiting expensive, untrained staff, trying to build a file with patchwork data, and relying on manual processes.  On the other hand, it says that best practices for a successful large-scale remediation process include rewarding clients, improving data quality, and prioritizing cost and time.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page, where contributions start as low as $3, 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

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