20+ years in financial crime. Senior Advisor at Handelsbanken. Former Head of Sanctions and AML. Founded two fintech companies. Writes about what AML compliance actually looks like in practice.
AMLA
AMLA has published draft guidelines on how every obliged entity should conduct its Business-Wide Risk Assessment under the AMLR. The scope now includes sanctions evasion risk, but the methodology is yours to choose. Here's what matters.
Sanctions
Authoritarian governments have found a way to weaponise our compliance infrastructure. The screening tools and de-risking practices we rely on daily are being used to extend political repression across borders — and the system is working exactly as designed.