Client due diligence and related processes in financial services – client acceptance, know your customer, anti-money laundering, sanctions monitoring – are central to modernizing and improving compliance programs. Current trends indicate that cultural differences, technological advances, and cooperation of enforcement authorities are all driving investigation and improvement.

• Culture of bribery in Africa as conventional “cost of doing business” under corruption scrutiny in investigation of British American Tobacco by the UK Serious Fraud Office:  British American Tobacco investigated by Serious Fraud Office
• Know your customer standards of anti-money laundering and illegal activity deterrence in conflict with bitcoin and cryptocurrency popularity among both criminals and mainstream users who want, in fact, to not be known or even to be seen as customers:  Bitcoin Site Fined $110 Million for Money Laundering, Owner Arrested for Hacking
• Facilitation of money laundering in branch locations of international banks and focused attention from regulators on non-local firms entering new markets brings into question expansion strategies for financial services organizations abroad:  Inside ICBC: How the world’s biggest bank became ensnared in a sprawling money laundering probe
• Despite established investigation and enforcement efforts and a long history of anti-money laundering programs as part of law and general practice, the United States is popular for the ease of incorporating anonymous shell companies, despite the intentions for their use:  The U.S. Is a Good Place for Bad People to Stash Their Money
• Money stolen from Bangladesh’s central bank via a hacker attack on SWIFT, the global system banks use to transfer money between each other, was laundered through Philippine casinos by Chinese baccarat players for weeks, even after Bangladeshi bank officials asked authorities in the Philippines to intervene:  A Baccarat Binge Helped Launder the World’s Biggest Cyberheist
• Criminals have been targeting children as young as 13 on social media to act as “money mules,” paying them to use their bank accounts to facilitate money laundering:  Gangs force thousands of teens to become ‘money mules’

In the ever-increasingly complicated global marketplace, client due diligence as a practice will continue to involve, taking into account local practices, changes in technology, and shifting regulatory priorities.