New staff, “front-line” staff, staff dealing with new customers, and supervisors and managers should be given appropriate training and refresher training, on AML/CFT policies and procedures. •  Finally, adopt a risk-based rather than rule-based approach. Seek to approach AML/CFT issues from a risk perspective, rather than a purely regulatory compliance perspective.
Look out systematically for products, customers and geographic locations that pose a higher risk of money laundering or terrorism financing. Of course, it would be a mistake to assume that money laundering and the need for proper controls are confined to the banks.