From a financial crime perspective, financial institutions, fintechs, and others should proactively seek to understand directly and indirectly via their vast counterparty networks their nexus to Afghanistan. Below are some proactive steps organizations can and should take to get in front of what to date has been a slow moving response from governments. For example, of the new FinCEN-issued National AML Priorities, several are directly relevant to the current situation in Afghanistan - including, but not limited to: i) corruption, ii) terrorist financing, iii) transnational organized crime and iv) drug trafficking.
Practical AML/CFT & sanctions mitigants in the wake of the Afghanistan collapse:
The above is not exhaustive, but should provoke some additional questions and thinking for proactive compliance teams.
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