The changes to reduce the level of prescription and move to a more risk based approach are welcome. They will assist organisations manage AML/CTF risk without prescribing a tick-in-the-box risk management culture. Reporting entities should not view a risk based regime as a lesser challenge. In our experience, the effort to assess, monitor and embed a sustainable risk management program will be substantial. This is particularly so in jurisdictions moving away from a well established reporting regime....

Key issues and impacts What should your immediate priorities be?....