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The Part One Recap

In part one we walked through pertinent legislative history; addressed the conflict model concept; and laid out five specific conflicts that appear apparent within the current U.S. AML Regime.

Guiding Principle #1

Design a shared value proposition of orchestrated government and industry collaboration.

Guiding Principle #2

Solidify desired outcomes and shared benefits of participation in a government and industry collaboration.

The Ideas

While prefaced as practical above — ideas or solutions to eliminate conflict may come across as disruptive for many that thrive in the model today. However, an acceptance by current participants to adopt the guiding principles is an imperative.

Policy vs. Action

The type of shift that is ultimately being suggested is one that moves the focus to action vs. policy discussion. The lack of organized, timely, and collaborative action (execution) over a 50+ year regime is evident in the known failures of combatting financial crime. The policy talkers gave it a shot — let the next regime focus on action measured by results. The “CDD rule” first appeared publicly circa 2014 as a notice of proposed rule making. Six years later it still dominates policy talk and offers nothing but confusion and distraction to industry.

Synthesized Thoughts

Value proposition, shared outcomes, shared benefits, collaborative strategies — without these guiding the regime conflict persists and the blur between good actors and bad actors lingers.

Thought Leadership Series
An Article by Vic Maculaitis, CAMS
Founder & Chief Executive at THE DATA INITIATIVE

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