KYC AML Guide: the Clock shows the average reeding time of the blog11 min Read


KYC AML Guide: the Clock shows the average reeding time of the blogSeptember 19, 2023

AML Challenges in the Screening Process

Anti-money laundering (AML) regulations are required to protect the global financial system from illegal activities. One of the most important aspects of AML compliance is the screening process, which involves investigating customers, transactions, and companies to identify and report suspicious activity. However, this seemingly simple task is not without its difficulties. In this blog, we will look at some of the most significant AML challenges in the screening process

Misbah Tayib

Compliance Journalist

What is the AML Screening Process?

AML screening is a critical process aimed at preventing and detecting illegal financial activities such as money laundering and terrorist financing. Its goal is to detect and combat suspicious transactions and practices, as well as to ensure that individuals and organizations follow AML regulations. AML screening has three main facets:

  • PEP Analysis is the examination of people with highly visible positions in government or other public sectors including their close relatives and associates (CRAs) to assess their risk in financial transactions.
  • Crime and AML Watchlist Screening compares individuals to databases of known or suspected criminals, including those involved in money laundering. terrorist.
  • Sanctions Screening compares people’s information to a government-provided restriction list to identify any connections to approved companies or activities.
  • AML name screening involves the comparison of individual, company, and country names against comprehensive lists that encompass various sanctions and risks related to financial crimes like money laundering and terrorist financing

The Importance of Conducting Proper Screening

A thorough AML screening is critical for many reasons. It assists businesses in ensuring the safety of their operations, protecting both themselves and their customers. Compliance with AML laws is maintained through proper monitoring, which improves reputation and avoids penalties for noncompliance. It includes several key components, such as Customer Due Diligence (CDD) and Knows Your Customer (KYC) procedures, Transaction Monitoring, Ongoing Monitoring, and Suspicious activity reporting. Furthermore, it contributes to global efforts to combat money laundering, terrorism, and organized crime by preventing such activities within its industry and sharing knowledge on a global scale. Finally, conducting a proper AML investigation is not only a good thing to do, but it is also a necessary and legal requirement for organizations of all sizes and shapes to protect themselves from money laundering and to comply with regulatory requirements.

AML Challenges in the Screening Process

However, it’s important to keep in mind that AML screening is not without challenges.

The Complexity of Money-Laundering Methods

Criminals are notorious for their adaptability, constantly devising new ways to launder money and avoid detection. Money launderers use a variety of tools to conceal the origins of their illicit gains, including shell companies, offshore accounts, and digital currencies. Furthermore, complex transaction techniques such as layering and integration complicate efforts to track down the source of funds.

Data Security and Privacy

As financial institutions collect more personal information about their customers in the digital age, there is growing concern about data privacy. Protecting sensitive information and adhering to data protection regulations is critical, necessitating a delicate balance between strong customer reviews and respecting customer privacy rights. According to IBM’s Cost of a Data Breach Report, the average cost of a data breach is $3.86 million, and this cost is rising.

Example: A bank’s customer database contains a large amount of personal data, such as financial records and identification documents. Unauthorized handling or access to this data may result in violations of privacy and legal consequences. As a result, when screening potential customers, financial institutions must implement strong data security measures to protect customer information.

False Positives

The frequent occurrence of counterfeiting caused by diagnostic tools is one of the AML challenges in the screening process. These false alarms occur when the customer’s name matches one of the names on the sanctioned list. Over 95% of AML alerts are false positives, costing companies over USD 3 billion annually, with an industry average of around 42% and rates as high as 95% for larger institutions. Financial institutions are responsible for devoting significant resources to investigating and correcting these irregularities, thereby avoiding unnecessary delays or denying valid transactions.

Assume a bank’s analytics tool generates an alert due to a name match between a customer named “John Smith” and a name on the sanctioned ist. Determining and confirming that this “John Smith” is not an authorized person can take time and resources, reducing the efficiency of the screening process.

Data Quality

Data that is inaccurate, incomplete, or inconsistent can result in false positives, missed suspicious activities, and regulatory noncompliance. It is critical for robust AML processes to maintain high data quality standards.

For example, if a bank’s database contains outdated or incorrect customer information, it can impair the accuracy of transaction monitoring and customer due diligence. This could lead to genuine suspicious activities going unnoticed or legitimate customers being subjected to unnecessary scrutiny.

Dynamic Watchlists

Regulations, global events, and emerging risks all cause watchlists to change frequently. Keeping up with these dynamic lists and incorporating updates into screening processes as soon as possible is critical for effective compliance. According to a Thomson Reuters survey, 57% of respondents said managing the vastness of data sources is the most difficult challenge in real-time sanctions screening, while 48% said monitoring payment flows is difficult.

For example, the addition of new individuals or entities to watchlists in response to international developments, such as sanctions against specific countries, necessitates financial institutions quickly adjusting their screening procedures to avoid engaging with sanctioned parties inadvertently.

Cross-Border Complexities

The globalization of finance increases the number of transactions and cross-border 

collaboration, complicating potential customer research. When selecting clients from different countries, financial institutions must navigate a plethora of laws and regulations. This frequently necessitates the use of multiple data sources and languages, which can result in inconsistencies and inefficiencies in the research process. In a 2022 Global AML Compliance Trends webinar, it was stated that managing cross-border and multi-jurisdictional AML compliance standards is a challenge for businesses.

For example, an international bank investigating clients may discover clients from various jurisdictions, each governed by a different set of laws. Analyzing these clients effectively necessitates access to data sources in multiple languages as well as knowledge of various compliance standards. It can be difficult to ensure consistency and accuracy in a complex environment.

Regulatory Complexity

The complex web of regulations that govern the process is another significant challenge in the screening process. These regulations apply to a variety of restrictions imposed by various countries and international organizations.

For example, an international financial institution must be aware of restrictions imposed by various countries, such as trade embargoes or anti-terrorism measures. To ensure compliance with regulatory requirements across jurisdictions, compliant organizations must constantly update review criteria to align with the most recent PEP, sanction, and watchlist.

Changing Sanctions Regulations

Sanction rules are constantly changing, necessitating vigilance to stay on top of the most recent guidelines. Based on global socioeconomic and political events, new individuals, businesses, or even entire countries may be added to or removed from sanction lists. Businesses’ required actions can also change, ranging from freezing funds to reporting to authorities. Some of them are

  • The FinCEN final rule
  • National Strategy for Combating Terrorist and Other Illicit Financing
  • Responsible Financial Innovation Act (RFIA)
  • 6AMLD.
  • Anti-Money Laundering Authority (AMLA)
  • Markets in Crypto Assets (MiCA)

For example, amid the Russia-Ukraine conflict, financial institutions all over the world were forced to quickly update their sanction compliance procedures. Staying up to date on such changes and global developments is critical for effective compliance with sanction procedures.

Risks of Emerging Technology

Emerging technologies such as artificial intelligence, virtual assets, cryptocurrencies, and digital payment platforms present new anti-money laundering challenges. On the one hand, cutting-edge AML software solutions, for example, can significantly improve transaction monitoring and risk assessment, allowing businesses to stay ahead of evolving financial crime tactics. Criminals, on the other hand, are increasingly employing these technologies, making it difficult for financial institutions to identify and mitigate these risks during prospect screening.

Example: Due to digital transactions being anonymous and swift, a fintech company that provides digital payment services has trouble screening customers. Criminals may exploit these features for fraudulent purposes, necessitating the adoption of advanced fraud detection and customer screening solutions by the fintech company to stay ahead of emerging threats.

Bottom Line

Numerous AML challenges in the screening process necessitate constant attention and creative solutions. Financial institutions must make investments in sophisticated screening tools, maintain up-to-date databases, ensure adherence to data privacy laws, and keep abreast of new threats and regulatory changes if they are to effectively tackle challenges facing anti-money laundering. They can strengthen their AML screening processes as a result, contributing to a safer and more secure global financial system.


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Misbah Tayib
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Misbah Tayib is a compliance journalist and freelance writer with almost 6-year long experience of covering developments in blockchain sector, crypto industry, AML compliance, privacy regulations, and relevant political advancements.