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It is easy to see why, in the context of the UK, such a law may be needed. Of the more than 460,000 Suspicious Activity Reports sent by UK banks to the UK Financial Intelligence Unit in recent years for suspicious transactions, the government’s Law Commission concluded that many were of “low-quality” and that many banks had a poor understanding of their reporting obligations, reporting less to assist the authorities than to avoid a law suit.
“US authorities have dominated the global AML landscape through the imposition of numerous huge fines for AML failings. But that has changed somewhat in recent years - US fine amounts have fallen while other jurisdictions, particularly in Europe, have imposed very large fines of their own,” explains Duff & Phelps’ head of UK regulatory consulting Nick Bayley.

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