ANALYSIS

Westpac AML / CTF failures

What went wrong?

PREPARED BY: DATE:

RiskScreen analysts July 2021

2
 Overview

On 22 October 2020 the Federal Court of

Australia (“the Court”) ordered Westpac
(“the Bank”) to pay a fine of A$1.3 billion.
The Court found that Westpac had
committed over 23 million contraventions
of the Anti-Money Laundering and
Counter-Terrorism Financing Act 2006
(“the Act”) 1 between 2013 and 2017.

Although the Court found that there had

been no deliberate intention on the part
of the Bank to breach the Act, this did not
displace the need for a significant penalty.
The Bank was given 28 days to pay the fine.

3 1
Paragraph 55 Judgment, CEO of AUSTRAC v Westpac Banking Corporation, [2020] FCA 1538
 Background

Westpac is Australia’s second largest lender 1. It failed to provide AUSTRAC with

by market capitalisation.2 AUSTRAC (Australian 19,502,841 reports regarding IFTIs within
Transaction Reports and Analysis Centre) is the requisite timeframe and failed to provide
Australia’s financial intelligence agency. In 76,144 IFTIs containing payer names;
November 2019 AUSTRAC issued proceedings
2. It failed to provide the requisite transfer
against Westpac and filed a Statement of Claim
information on 8140 IFTIs to another
containing allegations of AML/CTF3 breaches
institution and failed to pass on complete
committed by Westpac between 2013-2019.
payer information to another institution
in relation to 2,400 IFTIs;
The allegations fall into four general categories:
3. Between 15 March 2011 and 1 July 2016,
1. Inadequate reporting of millions of
it failed to retain records of transfer
International Funds Transfer Instructions
information in relation to 3,516,238
(IFTIs);
transfer instructions;
2. Failure to carry out adequate risk
4. Between 20 November 2013 and 20
assessments of correspondent banks;
November 2019, it did not conduct
3.
Failure to adopt and maintain an anti- adequate preliminary risk assessment
money laundering/ counter terrorism or due diligence of its correspondent
financing (AML/CTF) program; banking relationships on 48 occasions;

4. A failure to conduct adequate ongoing 5. Between 20 November 2013 and 20

due diligence and enhanced customer November 2019, Part A of its joint AML/CTF
due diligence. program did not comply with legislation.
Specifically, it did not have appropriate ML/
These allegations are examined in greater depth
TF risk assessments and risk-based controls
later in this white paper.
to enable the identification, mitigation
and management of ML/TF risks, having
The ignition event for the investigation by
a transaction monitoring program with
AUSTRAC was Westpac’s voluntary self-report
appropriate risk based systems and controls
in August 2018 of its failures to report IFTIs.
and having systems and controls to ensure
IFTIs are international fund transfers. Following
compliance with the obligation to report
this self-report AUSTRAC became concerned
IFTIs. The number of contraventions were
about the general control environment at
too many to quantify;
Westpac and broadened its enquiries. This
investigation culminated in the Statement 6. Westpac failed to conduct appropriate
of Claim. ongoing customer due diligence in relation
to 262 customers whose account activities
In September 2020 Westpac and AUSTRAC were consistent with indicators of the
came to an agreement. Westpac would pay funding of child exploitation material.
a fine of A$1.3 billion and an agreed statement The failure was systemic and occurred
of facts would be published by both parties. over a number of years.
The fine was ratified by Judgment of the
Federal Court of Australia in October 2020 2
Westpac to pay record fine to settle money laundering
(“October 2020 Judgment”). case, Comp. & Risk 2020, 9(5), 1,16

3
Anti-money laundering and counter terrorism financing
In the agreement statement of facts Westpac
made the following admissions:

4
 AUSTRAC had originally sought a finding against In December 2019, the Australian Prudential
Westpac’s Board, alleging in its November 2019 Regulation Authority (APRA) began a separate
Statement of Claim: investigation into Westpac’s risk governance
as a result of the AUSTRAC allegations.
"Systemic failures in its control
This investigation was delegated to Australian
environment, indifference by senior
Securities and Investments Commission (ASIC).
management and inadequate
Despite the work which the Bank had undertaken
oversight by the board." under the guidance of AUSTRAC, APRA, in
December 2020, remained concerned
Following this allegation, the Bank’s former CEO by the Bank’s progress in remediating compliance
and Managing Director, Brian Hartzer, stepped weaknesses across the organisation. APRA
down in November 2019 and the former Chairman, commented that the culture, governance and
Lindsay Maxsted, brought forward his retirement accountability program, which began in January
from December to April 2020. 2019, lacked sufficient momentum.6 APRA
determined that the Bank had an:
Ultimately, the allegation of Board indifference
was not pursued by AUSTRAC. The statement of
"immature and reactive risk
facts recorded that:
culture,unclear accountabilities,
"At all times the Westpac board and capability shortfalls and
senior management sought to ensure inadequate oversight." 7
that Westpac would comply with
Westpac's CEO Mr King issued a statement
its obligations under the AML/CTF conceding:
Act…Where issues were identified,
the board and senior management "While we have made progress in
sought to ensure these issues improving our standards, we have
were addressed." 4 much more work to do, and this
must be done at pace." 8
However, AUSTRAC and Westpac agreed that
some areas of money laundering and terrorism APRA agreed to a Court Enforceable Undertaking
financing risk were insufficiently understood (EU) from Westpac pledging to substantially lift its
in key areas of Westpac, compliance and risk efforts to address risk governance deficiencies.
management functions were inadequately ASIC concluded its investigation in December
resourced, and there was insufficient speed 2020. It did not take any enforcement action either
in addressing problems when they arose. against Westpac or any of Westpac’s employees. `

Between 2018 and 2020 Westpac worked In March 2021 APRA, after considering the results of
with AUSTRAC in order to assist in reporting, the ASIC investigation, closed its own investigation.
investigation and remediation of identified issues.
Westpac accepted that between 2013 and 2019 its
4
systems, controls, processes and resources were: Paragraphs 358 and 361, Statement of Agreed Facts
and Admissions

"not robust enough… to prevent 5

Overview of Westpac’s AML/CTF Compliance Failures
related to AUSTRAC statement of claim
issues in the AUSTRAC statement
of claim from occurring. Westpac 6
Westpac's AGM Groundhog Day, Australian Financial
Review, 7 December 2020
accepts full responsibility for its
7
mistakes and had admitted relevant Independent Review of Westpac Banking
Corporation’s Integrated Plan for the Court Enforceable
contraventions as part of the Undertaking, Promontory Australia, 5 March 2021.
AUSTRAC court process." 5 8
Ibid.

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 AUSTRAC's allegations

1. Failure in IFTI reporting specific bank. Again, these failures were not
brought to the attention of senior management.
The Act provides that every time funds are
transferred in or out of Australia, Westpac must The Group Money Laundering Reporting
report these transfers to AUSTRAC within 10 Officer only became aware of these issues
working days. Westpac have to provide the in May 2018 and reported them to AUSTRAC
identity of the payer, their address, the size of CEO in August 2018.
the transaction, what the payment is for and the
payee name and address. AUSTRAC alleged During the period October 2018 – September
that Westpac failed to comply with these 2019, Westpac reported 72% of all incoming
obligations in millions of instances. IFTIs late to AUSTRAC. 18 of the IFTI reports
which were lodged late with AUSTRAC related
As far back as 2013 the Bank was aware that to seven customers with which Westpac
its reporting functions of IFTIs were not had identified transactions indicative of
satisfactory. In 2013 AUSTRAC had queried the child exploitation and 19 related to suspect
Bank’s compliance with reporting requirements. transactions of 12 identified customers.
Westpac’s CTF/AML division prepared a report
looking into the efficacy of the IFTI reporting. The Bank traces its failings back to resource
The report identified that there were a number of: constraints when Westpac was changing and
upgrading its IT system in 2009. In 2011/12
"gaps… present in Westpac’s the Bank lost an entire team to another bank
structured IFTIs, ranging from responsible for the implementation of this
data quality, incorrect usage of program. These people were not replaced
XML tags, incorrect information because of resource constraints. 10 Simply put,
those who knew how to work the relevant IT
populated in XML tags and
systems left and there was a lacuna of the
incorrect definitions of
specialist knowledge that led to errors in
reportability." 9 implementation. There was no effective
review of the project after its implementation
However, it did not pick up on the fact that to check that it worked.
some IFTIs simply were not being reported.
Under the Act Westpac is required to
In July 2013 AUSTRAC recommended that keep records for seven years of each transfer
Westpac review payment instructions which instruction passed on to it by a correspondent
had not been reported to AUSTRAC. The bank. The Bank failed to do this in over 3.5
Bank duly did this and reported in June 2014. million instances. The simple reason was that
Again the review did not identify omissions the back-up system at Westpac wasn’t properly
in reporting. A management action plan was configured and as a result records were not
prepared by the Bank to address issues which retained and some lost. Again, Westpac did not
had been identified. The action plan also did have adequate assurance processes to pick up
not identify non-reporting as an issue. on this IT failure.

Employees of Westpac in May 2017 became

9
Paragraph 85 Judgment, CEO of AUSTRAC v Westpac
aware that IFTIs for a specific bank were not
Banking Corporation, [2020] FCA 1538
being reported. This failure was not brought
10
to the attention of senior managers. In August A mea culpa, not a fix: Australia’s biggest corporate
fine isn’t the end of it for Westpac, The Conversation,
2017 further employees of the Bank became
29 September 2020
aware of the same issues in relation to the

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 2. Failure to conduct adequate risk of the correspondent banking due diligence
assessments and due diligence assessment processes. These flaws could have
been addressed earlier had Westpac had:
assessments of correspondent
banking relationships
"stronger first line testing, second
Westpac had correspondent relationships line oversight and assurance and
with sixteen foreign banks. The risks of these third line audit coverage." 12
particular relationships are considered higher
by AUSTRAC as they involve the flow of money The Bank accepted it had not been compliant
across borders and incorporate jurisdictional risks. with the Act since 2013. Westpac accepted that
There is or can be a vast difference between the in some cases it did not appropriately assess the
AML/CTF processes and regulations in different jurisdictional risks of the correspondent banking
countries. There can also be a lack of transparency relationships and did not assess the impact of
in the identity of the customer and source of funds. higher ML/TF risks on banking services provided
by Westpac to the correspondent banks. It put this
Westpac had allowed offshore banks to use its non-compliance down to limitations in processes
domestic infrastructure to process Australian and procedures, failure to adhere to those
dollar payments to avoid transaction costs on processes and procedures in some cases
international transfers. AUSTRAC alleged that the and perhaps most interestingly
Bank was dealing with high-risk institutions which
were known to have relationships with sanctioned "reliance placed on a particular
countries such as Iraq, Lebanon, Ukraine, Zimbabwe
operational team to perform
and the DRC. AUSTRAC described the risk in the
functions that were critical to
following terms:
those due diligence process when
"The risk posed to Westpac was that role would have been better
that these high risk or sanctioned suited to those with particular
countries may have been able to financial crime expertise." 13
access the Australian payment
Westpac reports it has made the following
system through these nested changes to its due diligence processes:
arrangements, unbeknownst
to Westpac." 11 a. Enhanced the thoroughness of assessment
of the existence and quality of any AML/CTF
Prior to proceedings Westpac believed that it regulation in the correspondent bank’s
was compliant with the Act with respect to its country of domicile or that of its parent;
obligations for due diligence on correspondent
b. Off-loaded a large number of correspondent
banks. It had received confirmation in 2012 from an
banking relationships since July 2017 which
external review that its processes were compliant
do not meet its risk appetite or strategic
and that they were operating as they should. In
commercial objectives;
2016 AUSTRAC conducted an assessment of
Westpac’s compliance with obligations and made c. Conducted preliminary risk assessments and
seven recommendations to the Bank. AUSTRAC due diligence of all correspondent banks.
did not identify any non-compliance. The Bank
took steps to address the recommendations,
11
The Global Reach of US Coercion, Economic
however these steps were not adequate, the Court
coercion: Boycotts and sanction – preferred weapons
found. Westpac had engaged in relationships of war, David Uren, October 1 2020.
and transactions which were beyond its own risk
12
appetite. The Bank did not follow appropriate Paragraph 123, CEO of AUSTRAC v Westpac Banking
Corporation, [2020] FCA 1538
monitoring of these matters. The Court found that
there were flaws in the design and implementation 13
Overview of Westpac’s AML/CTF Compliance Failures
related to AUSTRAC statement of claim

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 3. Failure to adopt and maintain an anti- Whilst Westpac’s Part A required ML/TF risk
money laundering/ counter terrorism assessments for all new products or variations
to products, it didn’t include provision to update
financing (AML/CTF) program
those risk assessments in line with new or
emerging ML/TF risks.
As the October 2020 Judgment sets out, the
AML/CTF program is the principal document for
The Court found that Westpac’s transaction
setting out the risk-based systems and controls
monitoring program was seriously deficient. The
that are required to ensure compliance with
Judge criticised Westpac’s risk management
the Act and the Rules. Risk assessments are the
systems saying:
foundation of the obligation to identify, mitigate
and manage the ML/TF risks related to services
offered by the Bank. In order to appropriately "Clearly, this system failed to
manage and mitigate any ML/TF risk, the Bank properly identify, mitigate and
has to first identify and assess those ML/TF manage the money laundering
risks that it faces. AUSTRAC alleged that the and terrorism financing risks…
Bank failed to adopt and maintain adequate further Westpac’s transaction
AML/CTF programs. The Part A of the program
monitoring program was
relates to the Bank identifying, mitigating and
managing the risk of getting involved in, or
seriously deficient, that had
facilitating money laundering or CTF or other ramifications for monitoring
serious crime. AUSTRAC alleged shortcomings international payment flows
in the program and that Part A did not comply concerning billions of dollars
with Rules under the Act. AUSTRAC alleged that that had higher money
there were inadequacies in the Bank’s financial laundering risks including
crime system Detica and transaction monitoring
risks associated with child
and that remediation of the system had not
been adequate, timely or prioritised. The Part
exploitation and tax offences." 14
A Program did not include an appropriate level
of guidance to enable the Bank to identify 14
Paragraph 196 Judgment, CEO of AUSTRAC v
all relevant ML/TF risks stemming from new
Westpac Banking Corporation, [2020] FCA 1538
‘designated services’ offered to customers.

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 4. Failure to conduct appropriate AUSTRAC identified that there were twelve
ongoing customer due diligence customers on whom that the Bank failed to
conduct ongoing due diligence. Three of the
in relation to 262 customers
customers identified had prior convictions
relating to child exploitation offences and
In 2013 AUSTRAC produced Guidance for
one customer had been arrested in relation
institutions which identified patterns of
to further child exploitation offences since
transactions or ‘typologies’ which could
proceedings began in 2019. The Guardian
be linked to child exploitation. In 2016
reports that one customer made payments
The Commonwealth Attorney- General’s
to someone in the Philippines who was later
Department published information on the
charged with:
same topic. One of the recognised typologies
was that frequent guardirafficking. In December
2016 and 2017 AUSTRAC provided Westpac “live streaming of child sex shows
with methodology briefs detailing the key and offering children for sex.” 16
indicators for the purchase of live-streaming
exploitation material. Another Westpac client, ‘Customer 5’,
reportedly paid $75,000 over four years and
In 2016 Westpac had identified that low-value repeatedly travelled to south-east Asia. 17
payments to the Philippines were increasing
and this represented a risk in terms of child The Bank accepts that it failed to adhere to the
exploitation. As a result, Westpac introduced Guidance produced by AUSTRAC. Furthermore,
a ‘detection scenario’ into a payment channel. those individuals responsible for digesting the
However, this detection scenario failed to Guidance and then applying it to individual
detect any issues and did not adequately reflect situations did not fully understand or take on
the Guidance. The detection tool was replaced board that Guidance.
in 2018 but to only one of its payment channels
and not across all of them. The Bank, according Westpac reports it has made changes to its
to AUSTRAC, continued to fail: enhanced customer due diligences processes
for those customers who have been identified
"to identify activity indicative in suspicious matter reports filed with
of child exploitation risks." 15 AUSTRAC including:

In 2019 a bank teller identified potentially a. Reducing the maximum time permitted
suspicious activity as a result of a face-to-face for ‘exit decisions’ to be made in relation
to those accounts;
encounter with a customer (‘Customer 12’ as
referred to in the statement of facts). The bank b. Blocking certain payments for those
teller raised a red flag in relation to Customer customers who are subject to an exit
12, who had made a number of payments to the decision in the period between the
Philippines. Customer 12 was investigated by suspicious matter report being filed
the Bank and it transpired that the customer and the customer account being closed;
had a previous conviction for child exploitation
c. Additional training for staff in relation
offences. Due diligence had not picked this up
to identifying and monitoring child
beforehand. Customer 12 had had an account
exploitation material risk.
with Westpac since 2001. It took Westpac
2.5 months to close Customer 12’s account.
15
Between raising the red flag and the closure https://theconversation.com/westpacs-panicked-
of Customer 12’s account, no heightened response-to-its-money-laundering-scandal-looks-ill-
considered-127700
restrictions were in place and the customer
made nine low-value transfers of money 16, 17
https://www.theguardian.com/australia-news/2019/
consistent with child exploitation. nov/21/what-is-westpac-accused-of-and-how-is-this-
related-to-child-exploitation-explainer

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 What lessons were learnt?

In response to the allegations made by The evolution of the regulatory environment

AUSTRAC, the Bank commissioned a report by in Australia moved faster than the Bank was
an Independent Advisory Panel (“the Report”) to able or willing to. Management systems, data
examine the Board response to its obligations analytic resources and processes were not
to deal with the AML/CTF. Three primary causes sufficiently nimble to keep abreast of regulatory
of the AML/CTF compliance failings relating to requirements. Clearly the implementation
the AUSTRAC allegations were identified: and continual investment in an effective IT
screening and monitoring program should
1. AML/CTF risk was not always well have been made a priority. The Australian
understood across Westpac. The Bank reports that Westpac had a:
did not understand the need for specialist
capabilities to manage that non-financial risk; "perennial underinvestment issue
2. Individuals at the operational level in the on financial crime technology,
Bank did not understand where their systems and execution." 19
responsibility started and ended. The
application of the three lines of defence The Bank accepted that there were
model did not always operate effectively weaknesses in the data management and
when it came to AML/CTF risk; technology systems in relation to AML/
CTF compliance and that the AML/CTF
3. There was insufficient expertise in the compliance and risk management functions
financial crime arena within the Bank and were not adequately resourced. However, it
too few employees with the requisite skills, would seem that despite recent investment
experience and expertise to effectively in its IT technology it still leaves a lot to be
manage the AML/CTF risk. desired. Employees at the Bank complained
in a report in July 2021 that in comparison to
The Report examined possible deficiencies in CBA, the technology at Westpac is ‘medieval’. 20
the Board and found that overall the governance Apparently subsidiaries of Westpac have not
at Board and Committee level was good. been integrated onto one IT system, meaning
However, the voice of financial crime risk was that any compliance task that needs to be
quiet against the background noise of other completed can take two to three times
issues within the Bank. It was not given the longer compared to at CBA.21
priority it deserved until 2017.
A significant problem for the Board was that
The Report described the Bank’s program despite receiving regular reports and updates
to manage AML/CTF risk as ‘immature and in relation to AML/CTF, the information within
inadequate’ early in the period, a description Mr these reports was incomplete or misleading.
King, the Chief Executive of the Bank, accepted: This is, as the Report identifies, a significant
problem for the Board when there are
"We completely accept that blockages in the information flows.
some important aspects of
Westpac’s financial crime 18
Westpac releases findings into AUSTRAC statement
risk culture were immature of claim issues, 4 June 2020.

and reactive, and we failed 19

Westpac limits the damage, The Australian, 25
to build sufficient capacity September 2020

and experiences in 20, 21

Dirty Money: How the banks and AUSTRAC are
important areas." 18 fighting back against financial crime, WA Today, 3 July 2021

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 The Report goes on to comment that before d. Monitor AML/CTF compliance;
2017 the Board’s responses to known risks were
e. Observe and learn from global best practice.
slow off the mark. The financial crime team
and leadership within the Bank lacked relevant
international experience. They did not recognise The Bank has made efforts to implement some
global trends in financial crime and enforcement of these recommendations and reportedly has:
activity. This, the Report comments, is perhaps
unsurprising given the largely domestic profile a. Held a training workshop for the Board
of the Australian retail banks and the focus of members on financial crime, and increased
AUSTRAC on tax evasion, welfare fraud, terrorism resources for this area;
and organised crime. It was not until 2010 that
b. Appointed individuals with relevant
AML/CTF became a considerable part of any Bank
international expertise at Board and
risk management agenda. The CBA penalties in
executive level.
2017 sent a shock through Australian banks and
encouraged a change in assessment, management c. Hired hundreds more staff to deal specifically
and monitoring of non-financial risks. with AML/CTF. The Bank’s core financial team
is made up of permanent employees and not
The Three Lines of Defence framework22 which temporary contractors which some staff say
was employed by the Bank had ‘shallow roots’ leads to a cohesive culture;
in the financial crime risk area. The Board
wrongly assumed that the Three Lines of Defence d. Upgraded its technology. The Bank since
framework was sufficiently established and robust. 2014 had spent A$632 million on financial
Directors did not react urgently to reoccurring red crime compliance, including AML/CTF
flags. There was a lag between Board engagement compliance and made improvements to its
with the AML/CTF obligations and the expectations technology platforms, personnel, processes
of AUSTRAC. The Bank accepted that the Three and procedures. However, as above, it would
appear that there is much work still to do
Lines of Defence model was:
on that front;

"not consistently understood e. In June 2020 a new Group Executive, Financial

and embedded in the Bank." 23 Crime, Compliance and Conduct was appointed
who reports directly to the CEO. Those who
There was not sufficient clarity and understanding work at the Bank have said that this has changed
within Westpac as to the particular accountabilities the Bank’s approach to risk. One manager
between the three lines of defence responsible for working in financial crime said:
financial crime controls. Roles, responsibilities and
accountabilities were often misunderstood, which: "when you have a higher seat at
the table, you pretty much have
"blurred boundaries and meant some the full support from the board." 25
things fall through the cracks." 24
22
The Report made a number of recommendations The first line of defence is risk identification, risk
management and self-assessment. The second line of
as to how Westpac could improve governance at
defence establishment of risk management framework
the Bank such as: and policies and risk management oversight. The third
line of defence is Group Audit.
a. Improvements in end-to-end financial
crime risk management processes and 23
https://www.theguardian.com/australia-news/2020/
establish clearer accountabilities for jul/17/westpac-admits-it-has-failed-to-fix-culture-that-
contributed-to-money-laundering-scandal 1
AML/CTF compliance;
24
Regulation Asia, Lessons Learned from APAC’s
b. Embed and clarify the three lines of defence
Landmark Year of AML Fines, 19 January 2021
model in the financial crime arena;
25
WA Today, Dirty money: How the banks and AUSTRAC
c. Rebuild the relationship with AUSTRAC; are fighting back against financial crime, 3 July 2021

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 How RiskScreen technology
could have helped Westpac
avoid AML failure

First and foremost, the Westpac scandal is about lack of

effective oversight and risk governance. Woeful inadequacies
were not identified and, to the extent they were, were not
acted upon in an effective and timely manner. The scandal
highlights the criticality of effective real time MI to ‘fuel’
competent oversight and decision making.

The scandal also highlights the importance of risk-based

in-life customer monitoring to enable timely reporting of
relevant transactions to the authorities.

The fundamental learning point from the scandal is the

need for integrated IT systems that manage client screening,
onboarding, and ongoing monitoring effectively at all points
of the customer lifecycle; and thereby facilitating:

• Dynamic monitoring of customer AML risk

• Timely detection of suspicious activity

• Effective reporting

• Competent governance of AML risk through

timely production and reporting of MI in relation
to individual customers and groups of customers

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 RiskScreen's award-winning technology

RiskScreen’s onboarding, screening and in- • Advanced customisable reporting

life monitoring solutions enable businesses to functionality, enabling senior
effectively deploy the risk-based approach to
managers to dynamically interrogate
tackle money laundering and financial crime.
areas of AML compliance weakness

The following RiskScreen capabilities would • A direct link to RiskScreen’s 3D

have materially improved Westpac’s AML batch screening software, creating
compliance effectiveness: operational efficiencies through
a reduction in false positives of
• Data collection from end-customers up to 95% - with no reduction in
via a customisable, secure external true matches.
onboarding portal and smartphone
eIDV app With the diverse coverage and capabilities
provided by RiskScreen’s AML solutions,
• Customer data integration into many of Westpac’s problems could have
a single in-life monitoring platform, been avoided. The bank would certainly have
including full headless integration benefitted from vastly better MI reporting and
earlier detection of critical issues.
of the RiskScreen modules with the
bank’s core platform
The main lesson from the Westpac scandal
is that institutions with long-established AML
• Dynamic risk-based monitoring of all
programs continue to get AML wrong, and
customer relationship and transactions
must not be complacent. These ongoing
failures in people, processes and technology
• Dynamic risk-based alerting
perpetuate the poor return the industry gets
functionality
from its vast compliance spend. We should
all be smarter than that.
• Full audit capture

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 About RiskScreen

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of AML onboarding, screening and in-life
monitoring technology.

Established in 2016 by the original founder of the

International Compliance Association, RiskScreen’s
subject-matter expertise is unparalleled.

We partner with the world’s leading data businesses,

and are trusted by hundreds of enterprise customers
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money laundering.

Visit riskscreen.com Email sales@riskscreen.com

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