Stepping up privacy controls in AML

“Stepping up privacy controls in AML” A sponsored Report.


This report is commissioned by Clingstone Limited and Sheperdine Sand Limited.


WHAT:  a Report on “Stepping up privacy controls in AML” is prepared by Dr Dionysios Demetis, a lecturer at University of Hull with research interests in AML and Systems Theory. Dr Demetis is one of the leading domain experts who was a key contributor to Spotlight EU project, as well as the GATE EU Project targeting Money Laundering and Terrorist Financing. Dr Demetis is an author of a large number of AML research deliverables for the European Commission and the Future of Identity for the Information Society (FIDIS)

FOR WHOM: This report would be of interest to senior level Compliance and Operations managers working on solutions to model a ‘risk-based’ approach to AML for their organisation.

WHY:  “There are important considerations at the intersection of privacy and Anti-Money Laundering. By being informed about this changing landscape, Money
Laundering Reporting Officers (MLROs) and Compliance Officers can steer their own internal processes accordingly. ”


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“Over the past two decades, Anti-Money Laundering legislation has had a considerable impact over how financial institutions have introduced initiatives to tackle money laundering. In doing so, they have often introduced controls, processes, and procedures and technology that have overstepped (and even ignored) privacy considerations. The latest fad of ‘Big Data’ is yet another development that is seen by many as one more privacy-troubling step.  

Amidst these evolutions, an important development sheds some additional light into the domain of privacy and how this should be considered. This is “The Working Party 29 (WP29) of the European Commission recommendations on Privacy and Anti-Money  Laundering”. This report reflects the author’s commentary on these developments from a privacy/information-management perspective.” 

Dr Dionysios Demetis  
Hull University Business School

OCTOBER 7, 2015