Over 100 industry professionals recently gathered at the George Town Yacht Club to gain insights into one of the most significant anti-money laundering (AML) failures in recent banking history. Hosted by CIBA, and presented by PwC, this session focused on a $3 billion enforcement action and provided critical lessons on regulatory risk, cultural failures, and the importance of modern compliance frameworks.
Kelli Dawson, Ciara Plunkett and Donna Anderson from PwC led the discussion, offering a detailed analysis of the compliance gaps that contributed to the historic penalty. They outlined how outdated systems, weak internal controls, and a lack of accountability created opportunities for illicit activity to go undetected.
They outlined how the institution failed to file accurate suspicious activity reports and left its transaction monitoring systems unchanged for years. During that time, new threats emerged but were not addressed, leaving the organisation exposed and unprepared. The PwC team emphasised that compliance should not be static and must evolve alongside growing threats and regulatory expectations.
One example involved a seemingly low-risk business whose account activity revealed unusually large volumes of international transactions flowing through high-risk jurisdictions. Despite multiple red flags no action was taken—due to outdated risk classifications and insufficient monitoring. The case highlighted how static data and a lack of timely reviews can lead to major compliance failures.
As part of the case study, CIBA members examined the impact compliance culture had on the organization. While some staff were complicit, others lacked the training or confidence to report suspicious behaviour, pointing to deeper cultural issues within the institution.
The discussion reinforced the need for regular scenario testing, greater investment in staff training, and better alignment between governance and daily operations. Attendees were encouraged to assess their own frameworks and take action to close any existing gaps.
PwC’s presentation offered practical, relevant takeaways for strengthening AML programmes.
For more updates on future events, visit https://cibankers.org
PwC Contact Details:
Kelli Dawson – kelli.dawson@pwc.com
Ciara Plunkett – ciara.plunkett@pwc.com
Donna Anderson – donna.anderson@pwc.com
