Why is it essential for the first level of control, particularly in terms of AML/CFT, to be properly applied by operational staff?

Paris, France, March 15, 2023 – The effectiveness of the anti-money laundering system relies on a multi-tiered approach, with each level of control playing a vital role. However, it is particularly essential for the first level of control, executed by operation staff, to be diligently implemented.

The first level of control is carried out by the institution’s employees, who bear the responsibility of enforcing vigilance obligations and detecting suspicious transactions.
Should the first level of control prove deficiency is deficient, hinting that employees are inadequately trained, lack awareness, or are disengaged in the fight against money laundering, the system’s integrity will be compromised.
In this case, the second level of control, known as the compliance department, will be rendered ineffective.
The latter is indeed responsible for monitoring and ensuring the implementation of anti-money laundering prevention procedures, based on the information and reports provided by employees within the institution.
If the information and reports are insufficient or delayed, the compliance department will struggle to fulfill its mission effectively.
It is therefore crucial that each level of control operates proficiently and that every employee within the institution is actively ENGAGED in the fight against money laundering.
A weakness at any level can lead to overall inefficiency and increase the risks for the financial institution.

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