Blanket AML De-Risking: Risk Avoidance vs. Risk Management

Aleksandra Mejertale, CAMS

This White Paper aims to raise awareness about de-risking phenomenon, describing the key aspects of it and providing arguments about how banks should manage ML risk, as opposed to avoiding it by unnecessarily terminating customer relationships with the entire categories of customers. Furthermore, this white paper seeks to discuss how auditors, including regulators, need to address the de-risking issue: cooperating with banks, supporting and encouraging them to effectively implement a risk-based approach as required by the AML leading practice, neither supporting blanket AML de-risking approach, nor forcing banks to apply it.

Download PDF