Enterprise-Wide AML Visibility vs Business Unit Independence

Implement centralised AML intelligence with federated operational ownership so group-wide risk visibility coexists with local investigation accountability.

CyberTRIZ analysis · Banking contradiction AML029 · one of 8,235 worked contradictions published by CyberTRIZ.AI

Regulations

FATF BCBS_239 BE_NBB_GOVERNANCE_MANUAL_2022 COBIT2019 EU_SANCTIONS

Business Context

Large banking groups require consolidated AML visibility across retail, commercial, private banking, investment banking, and international subsidiaries, while individual business units maintain operational independence.

Banking TRIZ Resolution

Implement centralized AML intelligence supported by federated operational ownership, allowing local teams to manage investigations while sharing enterprise-wide risk information.

Recommended Banking TRIZ Principles

Principle 5 - Merging

Principle 17 - Another Dimension

Principle 24 - Intermediary

Principle 40 - Composite Materials

Expected Outcome

Better enterprise visibility

Improved collaboration

Stronger governance

Lower financial crime risk

TRIZ principles applied

P5 MergingP17 Another DimensionP24 IntermediaryP40 Composite Materials

Controls that address this (13)

FATF-AML-001 - Implement Risk-Based AML/CFT Approachoperational · critical priority · Implement a risk-based approach to AML/CFT covering: national risk assessment awareness, institutional risk assessment, risk-based allocatio FATF-CDD-001 - Implement FATF-Standard Customer Due Diligenceoperational · critical priority · Apply CDD measures to all customers: identify and verify customer identity, identify beneficial owners, understand the purpose of the busine FATF-R1-001 - Institutional AML/CFT Risk Assessmentgovernance · critical priority · Conduct a comprehensive institutional AML/CFT risk assessment covering: products and services, customer types, delivery channels, and geogra