A compliance officer should consider the following three factors as part of the approach to implement an enterprise-wide anti-money laundering program for a bank that operates in multiple countries:
* The types of customers serviced by the bank: Different types of customers may pose different levels of money laundering risk, depending on their nature, source of funds, geographic location, transaction patterns, and other factors. A compliance officer should identify and assess the money laundering risk associated with each customer type and segment, and apply appropriate due diligence measures, monitoring systems, and risk mitigation strategies accordingly12.
* The extent of anti-money laundering regulations in the various countries: A compliance officer should
* be aware of the legal and regulatory requirements and expectations for anti-money laundering compliance in each country where the bank operates, and ensure that the bank's policies and procedures are consistent with them. A compliance officer should also monitor any changes or updates in the anti-money laundering laws and regulations in the various countries, and adjust the bank's program accordingly34.
* The anti-money laundering risk posed by the products and services offered by the bank: Different products and services may have different features and functionalities that could be exploited by money launderers, such as anonymity, cross-border transfers, cash transactions, complex structures, or new technologies. A compliance officer should evaluate the money laundering risk associated with each product and service offered by the bank, and implement appropriate controls, safeguards, and oversight mechanisms to prevent and detect money laundering activities5 .
References:
* 1: ACAMS, CAMS Study Guide, 6th Edition, Chapter 2: Risk Assessments
* 2: FATF, Guidance for a Risk-Based Approach: The Banking Sector
* 3: ACAMS, CAMS Study Guide, 6th Edition, Chapter 3: Compliance Standards for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT)
* 4: Deloitte, AML Program Effectiveness Reform
* 5: ACAMS, CAMS Study Guide, 6th Edition, Chapter 4: AML Program Design
* [6]: OCC, Money Laundering: A Banker's Guide to Avoiding Problems
Reference:
https://www.fatf-gafi.org/publications/mutualevaluations/documents/more-about-mutual-evaluations.html

Explanation/Reference: https://egmontgroup.org/en

The activity of a teller distributing bank brochures to customers who regularly conduct cash transactions below reporting limits warrants further review. This is because the teller may be facilitating or encouraging structuring, which is a form of money laundering that involves breaking down large amounts of cash into smaller transactions to avoid detection or reporting requirements. Structuring is illegal and can expose the institution and the employee to civil or criminal penalties. The teller may also be acting as an agent or a recruiter for money launderers who use the bank's services to launder their illicit funds12.
References:
1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 2: Money Laundering Risks and Methods, p. 28-29 2: FATF Report: Money Laundering through the Physical Transportation of Cash, October 2015, p. 23-24,
http://www.fatf-gafi.org/media/fatf/documents/reports/money-laundering-through-transportation-cash.pdf