How I Uncovered Key Gaps Between FATF Recommendations and Bangladesh BFIU Guidelines
Photo by Mathias Reding on Unsplash Last quarter, while reviewing a batch of 80,000 MFS transactions for a leading fintech company in Bangladesh, I noticed a discrepancy in the reporting of suspicious transactions. The company was using a system based on FATF recommendations, but I realized that these recommendations didn't fully align with the Bangladesh BFIU guidelines. This discrepancy could lead to significant compliance issues and potentially large fines. In my experience, this is a common problem that many AML analysts miss. When I was working on a project with bKash, I was wrong about this until I dug deeper into the BFIU guidelines. It turned out that the guidelines had specific requirements for MFS transactions above BDT 100,000, which weren't being fully implemented. The core problem most practitioners miss The core problem is that many AML systems are designed with a one-size-fits-all approach, without considering the specific requirements of each country. In the ca...