AML POLICY
Napoleon’s legacy:
How 19th century thinking
skews AML in the 21st century
Editor’s note: This article is the first in a
series that examines how banks can better
assess geographical risk. Both at client
take-on and in transaction monitoring, geography plays a key role in helping banks carry
out their risk-based approach to AML compliance. The first article looks at how banks
determine which countries to risk rate.
I
n 1815, after nearly a quarter century of
constant war, Napoleon was close to
defeat and Europe lay shattered. Austria,
France, Russia and the United Kingdom, the
major powers at the time, met in the Austrian
capital to reassemble a broken continent.
The Congress of Vienna redrew the map of
Europe — shuffling duchies and principalities
between countries until it achieved a weak
balance among competing interests. In the
end, a political system emerged containing
39 sovereign states, and many more nobles
seeking to upg