In today’s world of growing AML compliance regimes, the AML Compliance Officer or the AML principal Officer cannot manage the entire AML function in isolation. No doubt that the AML Compliance Officer would have developed the robust AML framework – the internal policies and procedures, but these are of no effectiveness unless these are adopted and implemented in their genuine sense across all the levels of the organization.

Compliance encompasses contributions from all the company’s departments, bringing in all the employees on a common understanding to make diligent efforts to combat financial crimes and safeguard the company and the economy.

In this context, we will discuss the significance of employee engagement and contribution to advancing the company’s AML compliance function.

Understanding the concept of Employee Engagement and Contribution from AML perspective

Employee engagement or contribution is the level of staff’s involvement and dedication towards the organization’s work and goals. Engaged personnel are the employees who understand their roles and are committed to giving their best in fulfilling that role with a sense of ownership rather than a “working for others” approach. The engaged team always thrives on developing new skills that can contribute towards the sustainable growth of the business. With engaged employees or whole-hearted contributions from the employees, organizations tend to achieve their goals faster, building a solid brand while adhering to regulatory requirements.

Employers need to understand that when the employees feel engaged and contribute towards achieving the company’s targeted results, it boosts their morale and empowers them, developing a sense of pride in their work. Engaged employees strive to ensure compliance with the company’s policies and applicable regulations, putting the organization’s values and reputation at the highest priority.

When talking about AML Compliance, the employees’ contribution and engagement cannot be overlooked. When the engaged employees understand the AML regulations and internal AML/CFT policies, procedures, and controls, they can contribute towards its effective implementation.

AML principal Officer cannot singlehandedly ensure that the red flags are identified on a timely basis and accurately reported to the Financial Intelligence Unit. The employees’ awareness of compliance and their sense of responsibility to safeguard the company’s integrity is of utmost importance in identifying and preventing business exploitation.

In adverse cases, where the employees do not feel engaged, they may overlook the company’s AML program and adopt the “tick the box” approach to do their assigned tasks without understanding their responsibility of identifying and managing the financial crime risks.

Not just limited to performing own duties but engaged employees to contribute towards building a strong AML compliance culture. They participate in the AML training, discuss their observed cases, and encourage other employees to implement the AML measures effectively. They make deliberate efforts to encourage AML compliance through open communication and collaboration between the teams – internally and externally.

For employee engagement, the two critical aspects are the tone at the top, i.e., the effective leadership from senior management and their commitment towards compliance, and the second aspect is the recognition of the employee’s efforts and actions towards the AML program and self-motivation for safeguarding the business’ integrity. So, if the employees see that the management is investing their time and resources in adhering to the AML regulations and prioritizing the compliance functions over the business, they tend to follow that example to stay AML compliant and prevent any exploitation by financial crimes.

Given the appreciation of their contribution, the engaged employees invest their time in staying up to date with the regulatory amendments to ensure their efforts are in the right direction and aligned with regulations to avoid any non-compliance fines or reputational damages to the organization. Their knowledge and skills help the AML Principal Officer make informed decisions are AML compliance.

With employee engagement and contribution, the situation is favourable to both –

  • company, as the effectiveness of the AML program increases, the work environment adopts the compliance culture, better employee retention rate, and all the employees together work towards a common organizational goal,
  • the employees, as the job satisfaction and productivity of the employees are enhanced when employees feel engaged.


Contribution of engaged employees towards AML Compliance

The AML non-compliance calls for heavy penalties and loss of trust and confidence in the business. It tarnishes the organization’s reputation. The possibility of non-compliance can be minimized or even negated when all the company employees come together, understand their duties towards AML compliance and shield the organization’s integrity and diligently discharge their duties, taking complete ownership of the AML function.

With the knowledge and attention to detail, the engaged employees can contribute towards optimizing the existing AML policies and procedures implemented in the company. It is recommended that the AML Principal Officer seek employee feedback and input, promoting the sense of their efforts being valued. Not just policies, but rather the interviews with the employees and understanding their engagement with clients can help a lot in assessing the inherent risk of the business and evaluating the possible impact.

Further, with engaged employees, the process of Customer Due Diligence is smooth and accurate, ensuring the collection of complete identification details of the customers and evaluating the customer risk effectively. The employees know when the customer will be treated as high-risk and how to conduct Enhanced Due Diligence. Identifying and reporting suspicious transactions become easy and quick when the employees understand the AML compliance obligations and contribute towards the fight against financial crimes.

The engaged employees make the AML principal Officer’s task of imparting AML training simple and effective. Engaged employees understand their role towards AML compliance and attentively attend the AML training courses to stay alert towards ML/FT red flags and potential risk indicators while discharging their routine duties.

Employee engagement and contribution are essential for successfully implementing the AML policies, procedures, and controls to protect the business against financial crime vulnerabilities and non-compliance penalties and foster an AML compliance culture.


AML India’s AML Compliance journey!

Engaged employees contributing towards the company’s AML compliance functions are the ambassadors of the organization’s compliance culture, promoting a strong brand and building a complaint and healthy work environment.

With AML India’s experience and knowledge of international AML practice, we can assist your organization in developing AML-compliant business principles by customizing your AML program and imparting comprehensive AML training to the team.

Invest in employee engagement to strengthen your AML compliance efforts, protect the business against financial crimes and build a sustainable reputation among stakeholders.

About the Author

Jyoti Maheshwari


Jyoti is a Chartered Accountant and Certified Anti-Money Laundering Specialist (CAMS) with over 7 years of experience in regulatory compliance, policymaking, risk management, RegTech solution consultancy, and implementation. With an understanding of the different jurisdictional AML regulations, including PMLA, 2002 and IFSCA (AML, CFT, and KYC) Guidelines, has been closely working with clients to implement Anti-Money Laundering measures, including conducting Enterprise-Wide Risk Assessments, imparting AML training, etc.