Recent anti‐money laundering enforcement actions: lessons to be learned at others' expense

Purpose – To draw lessons learned from recent anti‐money laundering enforcement actions. Design/methodology/approach – After providing a brief introduction to the AML regime, this article reviews the recent high‐profile enforcement actions. The article then examines what compliance lessons can be learned from these recent cases. Put differently, the article attempts to identify those measures that firms can take now to avoid being subject to headline‐grabbing enforcement actions in the future. Findings – Lessons learned from key recent enforcement actions include the following: SAR filings matter and ensuring an adequate SAR regime means ensuring both systems and staffing are commensurate with an institution's activities; an AML program can only function well if it is calibrated properly to the risks that the institution's businesses face; business growth needs to be accompanied by AML compliance growth; as institutions expand globally, they need to consider how to apply their AML programs across geographies and to ensure that common best practices are being followed by all employees, wherever located; and financial institutions must ensure not only that they have written policies and procedures, but also that those procedures are followed in practice. Originality/value – Draws the most important lessons learned from recent key anti‐money laundering enforcement actions.