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AML (Anti-Money Laundering) refers to laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.
Banks and financial institutions are the primary gatekeepers of the financial system, making AML compliance a critical function.
Banks are vulnerable because they:
Handle large volumes of transactions
Offer cross-border transfers
Provide accounts, loans, investments, and trade finance
Enable digital and online payments
Without AML controls, banks can be used for:
Money laundering
Terrorist financing
Fraud and corruption
Tax evasion
Sanctions evasion
Regulatory penalties for non-compliance can include:
Heavy monetary fines
License cancellation
Criminal liability
Severe reputational damage
🇮🇳 India
Prevention of Money Laundering Act (PMLA), 2002
RBI AML/KYC Master Directions
Financial Intelligence Unit – India (FIU-IND)
🌍 Global
FATF (Financial Action Task Force) Recommendations
USA PATRIOT Act (U.S.)
EU AML Directives
Basel Committee Guidelines
1. Customer Due Diligence (CDD)
Also called KYC (Know Your Customer).
Includes:
Customer identification & verification
Address proof & identity proof
Beneficial ownership identification
Risk categorization (Low/Medium/High risk)
Enhanced Due Diligence (EDD) for:
Politically Exposed Persons (PEPs)
High-risk countries
High-value clients
2. Transaction Monitoring
Banks use automated systems to detect suspicious patterns like:
Large cash deposits
Structuring (smurfing)
Rapid movement of funds
Unusual international transfers
Transactions inconsistent with customer profile
3. Suspicious Transaction Reporting (STR)
If suspicious activity is detected:
Bank files STR with FIU-IND (in India)
Confidential process (customer not informed)
Mandatory reporting timelines
4. Sanctions Screening
Screening against:
UN sanctions lists
OFAC lists
Domestic watchlists
Terrorist databases
5. Record Keeping
Maintain customer records for 5–10 years
Maintain transaction history
Ensure audit trails
6. Ongoing Monitoring
AML is not a one-time process.
Banks must:
Periodically update KYC
Reassess risk
Monitor unusual behavior continuously
Retail Banking
Corporate Banking
Correspondent Banking
Trade Finance
Private Banking
Digital/Neo Banks
Cryptocurrency exposure
Roles :
Board of Directors
Board of Directors
AML Analysts
Relationship Managers
Relationship Managers
Responsibilities:
Approve AML policy
Oversee AML program
Investigate alerts
Perform CDD
Test AML controls
Modern banks use:
AI & Machine Learning
Behavioral analytics
Name screening tools
Transaction monitoring systems
Case management systems
False positives in monitoring
Cross-border regulatory differences
Increasing digital fraud
Shell companies & layered transactions
Cryptocurrency risks
Major global banks have paid billions in fines for:
Weak monitoring systems
Failure to report suspicious activity
AML in banking ensures:
✔ Financial system integrity
✔ Prevention of crime & terrorism
✔ Regulatory compliance
✔ Institutional reputation protection
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