The World Council of Credit Unions has urged the Basel Committee on Banking Supervision to strive for greater clarity in its recent "Sound Management of Risk Related to Money Laundering and Financing of Terrorism" consultative document.
Specific suggestions included clarification of the term "financial inclusion" as one relating to all members, not just those considered "financially or socially disadvantaged," according to a letter submitted to Wayne Byers, the Basel Committee's secretary general, by Michael Edwards, WOCCU vice president and chief counsel.
Edwards' letter also asked the committee to clarify that it is not mandatory for institutions to use expensive vendor-created compliance software and lists when the cost of such systems outweighs the potential benefits based on the institution's complexity and risk requirements relative to anti-money laundering efforts and combating the financing of terrorism.
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