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Anti-money laundering (AML)

Also: AML, AML/CFT, know your customer, KYC, customer due diligence, suspicious activity report

The laws, controls and supervision that keep criminal proceeds from being passed through the financial system to look legitimate: identifying customers, understanding their activity, monitoring transactions and reporting suspicion, to the international standard set by the Financial Action Task Force's Recommendations.

Our take. AML is a risk-based discipline, not a checklist, and a firm that treats every customer identically is spending its effort in the wrong places. Onboarding checks catch the obvious cases, but laundering often shows only in behaviour over time, which is why monitoring and a well-reasoned suspicion report count for more than a thick file of passport copies. Closing whole categories of customers to avoid the work pushes them into channels with no controls at all.

The stages the controls aim at

  1. Placement: criminal cash first enters the system, often split into smaller deposits or converted into instruments that draw less attention.
  2. Layering: the funds move through accounts, jurisdictions and entities to break the trail back to where they came from.
  3. Integration: the money reappears as apparently clean wealth, invested in property, businesses or financial assets.

From standard to programme

The FATF, an intergovernmental body, sets the standard in its Recommendations. They began as forty measures spanning criminal justice, financial regulation and cross-border co-operation, and the current text also covers terrorist financing and the financing of proliferation; countries are assessed against them in mutual evaluations. For a regulated firm they translate into a recognisable programme: a business-wide risk assessment; customer due diligence scaled to risk, with enhanced checks for politically exposed persons and higher-risk countries; identifying the beneficial owners behind companies and trusts; ongoing monitoring; record keeping; and reporting suspicion to the national financial intelligence unit.

Technology has changed the work more than the principles. Sanctions screening and transaction alerts are increasingly automated, and the hard craft is tuning them so analysts see real risk without drowning in false positives. The FATF's guidance on financial inclusion warns that rigid identity requirements can shut out people who lack standard documents, such as refugees, which is the argument for simplified due diligence where risk is genuinely low. AML is a core strand of financial risk and compliance, and it binds payment firms in banking, fintech and payments, including open banking providers, whose onboarding also leans on strong authentication.

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Last reviewed 26 September 2026 · Getting Digital