As banks, financial services firms, casinos and others continue to work on building their risk-based approaches to the new money laundering laws, some experts are concerned that boards of directors are not aware of the risks they are facing.

“There is a statutory obligation on boards and senior management to take responsibility for AML,” said one senior money laundering expert. “There is huge anecdotal evidence in the US and abroad of shareholder class actions; I know there’s one out there for AWB now. When is the argument going to go on the table as to what boards and senior management are doing and can do to get confidence, independent confidence, that what they’re being told and what they’re forking out — and not inconsiderable sums — is representing effective risk management?”

Another source, who also spoke on condition of anonymity said that if an organisation was publicly acknowledged as having facilitated money laundering or terrorism financing through failing to have effective controls and a share price drop resulted, shareholders may launch a class action.