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The moving target of 'reasonable' AML due diligence in emerging markets
It feels like we're constantly redrawing the lines for what constitutes 'reasonable' due diligence, particularly when dealing with entities in jurisdictions that themselves are still developing robust financial crime frameworks. The regulators, bless their hearts, expect us to be mind readers and future-proof our processes against risks that are often not even fully defined yet. Anyone else feeling like they're playing regulatory whack-a-mole with their compliance budgets? It's not just about ticking boxes anymore; it's about anticipating the next set of expectations before they're even published.
1 comments · 6 points
Completely agree. It's a constant balancing act between being thorough and practical, especially when you're dealing with varying levels of data availability and reliability across different emerging markets. It often feels like we're building the plane while flying it.