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A Global Study into AFC Culture – Have We Come Far Enough?

Consistent messaging on compliance priorities and additional investments in technology and staff training are needed to reduce AFC penalties across the global financial sector


    This Global Study is the result of a survey of 349 professionals, two roundtable discussions with chief compliance officers from major financial institutions and interviews with 11 executives from regulatory bodies and industry trade associations.


    The study found that, while most financial institutions and their senior managers have made clear inroads toward improving AFC compliance in recent years, significant steps are still needed to reduce the sector’s exposure.

    The most needed improvement is a greater investment in AFC technology. AFC culture could be improved with more training, additional staff and resourcing, a stronger effort to ensure that middle management embraced the compliance mandates of senior managers. Further investments are needed, but so is greater consistency when it comes to the global application of AFC policies and procedures.

    The study separately outlines the need to strengthen the core components of a strong AFC culture under four categories: (1) strategy and risk appetite, (2) tone from the top, (3) accountability and incentives, and (4) training and communication.



    Key Findings

    of respondents agree that their managers, peers, and colleagues lead by example in their behavior relating to anti-financial crime


    agree that managers, peers and colleagues would withdraw from a business opportunity due to concerns about financial crime


    agree that their organization is well equipped to deal with the level of AFC risk it is facing


    of surveyed professionals agree that there are sufficient skilled and trained personnel for AFC in their organizations


    of US respondents believe their institution has a strong “tone from the top”


    of European respondents believe their institution has a strong “tone from the top”

    Who Should be Interested?

    Traditional financial institutions including:

    • Entry level positions

    • Middle management

    • Senior management

    • Executives / board level

    • Individual contributor

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    Main Sectors

    • Investment banks

    • Insurance companies

    • Fintechs

    • Money Service Businesses (MSBs)

    • Retail and Commercial banks

    • Others

    About Our Partner

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    Oliver Wyman is a global leader in management consulting. With offices in 60 cities across 29 countries, Oliver Wyman combines deep industry knowledge with specialized expertise in strategy, operations, risk management, and organization transformation. Oliver Wyman is a business of Marsh McLennan [NYSE: MMC]. For more information, visit www.oliverwyman.com.