From policy to practice: Practical perspectives on AML, TBML and compliance effectiveness
My articles look at a problem I’ve seen again and again in banking: AML and compliance frameworks that look sound on paper but struggle in practice. I write about why policies fail in execution, why transaction monitoring so often underperforms, how trade-based money laundering exploits gaps in trade finance, and what happens to compliance controls when systems go down. Throughout, I focus on the issues that decide whether controls actually work, such as data quality, scenario calibration, frontline ownership and measuring outcomes over activity.
Each piece draws on more than 11 years in trade finance, treasury operations and second-line compliance, supported by guidance from the FCA, FATF and the Basel Committee. The articles were first published on LinkedIn, where you’re welcome to follow the series and join the discussion.
Measuring compliance effectiveness: Why activity is not the same as performance
Introduction Over the past decade, compliance functions have undergone significant transformation. Increasing regulatory expectations, evolving financial crime risks, and rapid technological advancement have driven financial institutions to strengthen their governance frameworks, enhance monitoring capabilities, and invest heavily in compliance infrastructure. Today, organisations routinely measure compliance performance through dashboards, key performance indicators (KPIs), key risk indicators…
Operational resilience in compliance functions: What happens when systems fail?
Introduction In today’s financial environment, compliance functions have become increasingly dependent on technology. Transaction monitoring systems, sanctions screening tools, automated reporting platforms, customer risk rating engines, and case management applications now sit at the center of Anti-Money Laundering (AML) and financial crime frameworks. These systems are designed to improve efficiency, strengthen oversight, and support regulatory…
Trade-Based Money Laundering: Understanding the Mechanisms, Risks, and Control Challenges within Global Trade
Introduction Global trade plays a central role in the modern financial system by facilitating the movement of goods, services, and capital across international markets. The expansion of international trade has contributed significantly to economic development, financial integration, and globalisation. However, alongside these benefits, global trade has also created opportunities for financial crime. One of the…
Beyond the Framework: The Real Weakness in AML Transaction Monitoring
Introduction Transaction monitoring sits at the heart of any Anti-Money Laundering (AML) framework. Regulators have been consistent and clear on this. The Financial Action Task Force (FATF) explicitly requires ongoing monitoring of customer activity, while the Financial Conduct Authority (FCA) continues to emphasise the need for effective systems and controls that can detect suspicious behaviour…
The Execution Gap in AML: Why Good Policies Fail in Practice
Introduction In my previous article, “Why Anti-Money Laundering Is No Longer Optional in the Financial Sector,” I discussed how AML has evolved from a regulatory obligation into a fundamental component of financial system integrity. I also briefly highlighted a critical issue within the industry that the gap between well-documented frameworks and their actual execution in…
Why Anti-Money Laundering is no longer optional in the Financial Sector
Introduction In today’s financial environment, Anti-Money Laundering (AML) is often described as a regulatory requirement. In reality, it is far more than that it is a fundamental component of financial system integrity and institutional resilience. From my perspective, the issue is not whether AML is important. That question has already been answered. The real issue…
