Anti-money laundering. This term describes the efforts of the private and public sector to prevent and deter money laundering. Sometimes, professionals working in the AML compliance department, in for example a financial institution, also deal with sanctions compliance. Although compliance with AML obligations does not equal compliance with economic sanctions obligations, there are key similarities such as the use of judgement, the adoption of a risk based approach. Another important link between AML and sanctions compliance is conducting customer due diligence to screen for bad actors, which include sanctioned persons or entities. Under some sanctions programs (e.g. OFAC’s Russia/Ukraine sanctions program), companies and financial institutions are responsible for screening their customers for sanctioned entities or persons who might be Ultimate Beneficial Owners (UBOs) holding at least 50 percent (see OFAC 50% Rule) ownership in these other customers.

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