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Building a strong AML culture

Building a strong AML culture

Does your organisation have a strong or weak ‘AML culture’? An organisation’s AML/CFT controls can be weakened by a poor AML culture. KPMG’s Forensic team have identified seven building blocks essential for a strong AML culture.


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An organisation’s Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) controls can be easily undermined by a poor culture of compliance. Strong AML culture in an organisation can help prevent shortcomings and help identify issues before they become a concern.

For an organisation to develop strong AML culture, management buy-in and involvement is critical. Managing ML/TF risks and implementing integrated controls to meet compliance objectives should not be done in isolation.  

Even where systems and controls are in place to comply with AML/CFT requirements, they can be circumvented, or minimum effort may be taken to "tick a compliance box" rather than actually mitigating risk.

Our Forensic team have identified seven building blocks essential to building a strong AML culture.

  1. Tone from the top
  2. Leadership engagement
  3. Quality monitoring
  4. Balanced interests
  5. Sufficient resourcing
  6. Business-as-usual
  7. Training and communication

The infographic below provide further explanation to each of the 7 building blocks.

Seven building blocks essential to strong AML culture



7 building blocks essential to strong AML culture

© 2021 KPMG, a New Zealand partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (KPMG International), a Swiss entity. All rights reserved.

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