Developing a Corporate Protocol for Investigating AML/Sanctions-Related Misconduct

Beate Prochaska

Compliance culture, on the one hand, requires defining expectations with regards to compliance with the external and internal requirements, corporate values and incentivizing desirable behavior and actions within the organization. On the other hand, it also requires a clear protocol for investigating and sanctioning misconduct especially when AML and Sanctions breaches have occurred.

This paper discusses the considerations in developing a corporate protocol for the investigation of AML / Sanctions-related misconduct from the identification of relevant cases to the reporting of the results and referral for a decision on disciplinary action.

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