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Have We Come Far Enough?: A Global Study into Anti-Financial Crime Culture

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4 June 2021

An Oliver Wyman Report Written in Partnership with ACAMS

Scandals over recent years have shown that some institutions are still failing to live up to their obligation to minimize the risk of financial crime. In 2020, fines for non-compliance with anti-financial crime (AFC) and related regulations exceeded $14.1 billion. These failures occurred despite many financial institutions spending hundreds of millions to transform their control processes and systems. The persisting and larger problem is not technical but cultural.

Oliver Wyman and the Association of Certified Anti-Money Laundering Specialists (ACAMS) conducted a review of the current state and trends of financial institutions AFC culture based on interviews of a dozen senior executives from both the public and private sector, roundtables of professionals and a survey of nearly 350 professionals.

While our findings confirm that most financial institutions and their senior managers have made clear inroads toward improving AFC compliance over the last decade, the respondents have highlighted a number of key programmatic areas where financial institutions still have limitations hindering the ability to fully embed a robust AFC culture. In particular these items include risk appetite, quality of knowledgeable staff, sizing of technology budget trainings, and incentives.

Access the full report: Have We Come Far Enough?: A Global Study into Anti-Financial Crime Culture