Bloomberg provides a stunning overview of the laundering of over $1 billion in oil proceeds that highlight the importance of execution of basic AML principles.

Some questions to consider when placing this case study in context of your AML program:

  • How is your organization handling secondary sanctions and  associated risks?
  • When analyzing originator-beneficiary relationships, how often are intra-bank transfers actually scrutinized?
  • How robust is your third-party due diligence, and how might you prioritize by customer, product or geographic risk?
  • Do your PEP and sanctions-screening programs account for secondary relationships and beneficial ownership through enhanced due diligence?
  • Is your AML program aligned with your company's anti-bribery/corruption programs, to include information sharing?