ACAMS Today Magazine (March-May 2011) Vol. 10 No. 2 | Page 63

AML POLICY definition of country. Under criteria laid out in the the Montevideo Convention, recognition from other countries was not needed. Beyond territory, population and government, a state only needed the capacity to enter into relations with other countries in order to be considered a country itself. To put it another way: if it looks like a country and acts like a country, it is a country no matter what other countries have to say. Using the Montevideo definition as a basis for geographical risk rating makes sense because it solves the limited-recognition problem. With a defined territory and popu- lation, established government and ability to enter into relations with other countries, the TRNC would be included. So would several other limited-recognition countries dotting the world. theory it wants to use when a new territory seeks to become a member of the club of countries. In reality, many countries select the more expedient theory to fit their policy and purposes. See below for additional unrecognized and limited-recognition jurisdictions around the world. Banks should do the same.   One of the challenges of international relations is that there is no supreme power to impose common definitions and approaches. Thus, the Declarative Theory of Montevideo exists today with the Constitutive Theory of Vienna — each country free to choose which Max R. Tappeiner, Global AML advisor, Royal Bank of Scotland NV., Amsterdam, Netherlands. [email protected] The views expressed in this article are those of its author and do not necessarily represent the views of the Royal Bank of Scotland Group. Other AML Black