KYC Reviews: The Dragon of AML Compliance Programmes
Written by Samantha Sheen | Jun 30, 2020 9:38:09 AM “It does not do to leave a live dragon out of your calculations, if you live near him.”J.R.R. Tolkien, The Hobbit Introduction The most common area of AML/CFT compliance programmes that organisations struggle with are in relation to KYC reviews, refresh and subsequent remediation work needed to update or patch up existing customer KYC information. It’s a tough nut to crack. This month the Jersey Financial Service Commission (“JFSC”) published feedback from its examination of firms required to comply with local AML/CFT regulations. Findings in relation to KYC reviews included: In over half of the firms who used reviews…