Anti-Money Laundering And Counter-Terrorist Financing
11 July 2019
Risks And Mitigants For Non-Regulated Companies
Reputational concerns and the growing focus of financial regulators on money laundering and counter-terrorist financing (CTF) are starting to have an impact on how non-regulated sectors of the economy view and address these risks. The United Nations Office on Drugs and Crime has estimated that the amount of money laundered globally on an annual basis is between 2% and 5% of global GDP, or between USD800 billion and USD2 trillion in current US dollars.1 The scale of the problem means that it is becoming increasingly unlikely that governments and regulators will allow breaches of anti-money laundering (AML) laws by non-regulated companies to go unpunished. Furthermore, ensuring that funds do not reach terrorists remains a key focus for governments and regulators globally.
Most commentary on AML issues focuses on regulated companies, which have been subject to significant additional AML and CTF requirements and enforcement for some time. In this paper, we examine some of the risks for non-regulated companies and explore how these risks might be better understood and mitigated.