Abstract

The financial industry maturity model (FIMM) for anti-money laundering (AML) described in this paper is a governance risk and compliance (GRC) framework that describes the essential business process components that are necessary for effective implementation of AML and combating the financing of terrorism (CFT) obligations. It has been devised based on two key fundamentals; the theory of maturity models which represent growth in capability as a progression through a series of levels and the extant international legislation, regulation and best-practice information that pertains to anti-money laundering. The key objective of the FIMM (AML) model is to ensure consistent execution of AML processes by facilitating the embedding of an AML risk aware and compliance culture in financial services organisations. (Note: for the sake of brevity we will only refer to AML in the paper to cover both AML and CFT).

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