SYSTEMIC LAPSES IN AML COMPLIANCE: DID SOME BANKS ENABLE GRAND CORRUPTION?
INTRODUCTION As corruption scandals involving politically exposed persons (PEPs) dominate national discourse, one critical institution has largely escaped meaningful scrutiny: the banking sector. These are the very institutions that processed, facilitated, and in some cases, seemingly ignored questionable transactions. The evidence is stark — vast sums of money moved through regulated banks, often originating from state accounts and ending in private hands. Many of these funds were then used to acquire high-value assets such as real estate. Given the existing regulatory frameworks and sophisticated compliance tools available, it is difficult to believe this occurred without at least the tacit consent — or wilful neglect — of the financial system. This suggests more than isolated lapses. It points to deep structural weaknesses and the possible erosion of risk governance within the banks involved. To understand how this happened, one must consider the classic three-stage model of mo...