Dick Cassin, writing in his FCPA Blog, has consistently raised the issue of Anti-Money Laundering (AML) in the wider battle against bribery and corruption. He set out some of his thoughts in a post entitled “9/11 and the FCPA”. He also speaks regularly about AML laws as one component of the ongoing battle against world-wide terrorism since 9/11and how that relates to anti-bribery and anti-corruption compliance. I thought about Dick’s writing and ideas while I was reading the survey released yesterday by KPMG, entitled “Global Anti-Money Laundering Survey 2011”. While this survey focused on the banking industry, there were many issues identified that are applicable to the wider compliance field. The survey is one of the continuing releases by KPMG that gives insight into what compliance practitioners are thinking, some of the challenges that they face and provides a summary of best practices which anti-bribery and anti-corruption practitioners can incorporate into their company’s US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act compliance programs.
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