All types of financial crime prevention have been
handicapped to some extent by the division of clearly
related activities into policy and operational silos.
ABC is no exception. Banks have separate teams and
policies for ABC, focused largely on the provisions
of the US Foreign Corrupt Practices Act and the UK
Bribery Act, and it is viewed as distinct from other anti
money laundering activities because of its focus on
employees and direct representatives of the institution,
and not on the activities of clients.
Read the full report.