Tied up in knots


Question: When is a risk not a risk?
Answer: When it’s a rule.

This joke, which is currently doing the rounds among anti-money laundering (AML) officers at US financial institutions, sums up the frustration many bankers feel with a vagueness at the heart of the US system of banking regulation, and particularly in the anti-money laundering area of banking supervision. The AML area was meant to be one of the first to shift from being rules based to being risk based, to keep it in line with the

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