AML compliance should be a focal point of any financial institution's planning process. Age, notoriety and venerability aren't legally admissible, and any officer found culpable for an AML lapse could be found culpable, regardless of the reputation of the organization they represent.
To wit, there are few institutions with more name recognition or history than the Catholic Church. Despite this, the Church has pursued a dedicated effort to ensure AML compliance, one which seems to have paid off: In its 2013 annual report, Autorità di Informazione Finanziaria (AIF), the Vatican's anti-money-laundering authority, boasted great progress. These developments were in no small part due to a more thorough internal risk assessment, as well as a greater focus on international cooperation.
In an interview with the Wall Street Journal, Rene Bruelhart, director of the AIF, described these efforts.
"It's also very important to get an understanding of who are the players that have an impact on the institution. You have the clients, the authorities, you have competitors, the media, you have people who have taken advantage of special circumstances, so you are trying to understand the field you are in, where your universe is, where you might find certain vulnerabilities," explains Bruelhart.
He went on to cite the increasing complexity of the global framework as a primary motivator in the need for new policies. Breulhart's decisions for the Catholic Church underlie one of the critical tenets of modern AML compliance: it's a difficult task that must be undertaken with the utmost care. Having a dedicated and streamlined system in place can help any institution better use its resources and avoid costly oversights, regardless of its age or pedigree.
