VENDORS KEEP PUSHIING HIGH TECH CDD SOLUTIONS – COULD THEY ENABLE A NEW MODEL FOR AML?

Vendors continue to roll out what they claim are ever more powerful CDD/KYC systems, helping enable compliance with increasingly comprehensive ultimate beneficial ownership (UBO) laws. But do these technologies offer the AML community the potential to consider a new model – focusing on robust CDD by obliged entities, without the need to report STRs, and relying on better financed law enforcement to demand information via subpoenas to firm up ML cases? A June (2022) paper from the Cato Institute, an American libertarian think tank, has made the case for ...


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