Is Your AML/CTF/CPF Policy Manual Written in Barista?
30/10/2025
You walk into a café. The board screams:
- V60 pour-over, single-origin, 92°C bloom
- Flat white, ristretto shot, micro-foamed
You just wanted COFFEE.
Now open your Financial Crime Prevention Manual:
- “Enhanced due diligence pursuant to AML/CTF/CPF Rule 8.2.1”
- “Predicate offence typologies with SAR escalation matrix”
Same sin, different cup.
- Both the barista and the compliance writer fell in love with their own lingo.
- They turned “watch for money laundering” into a cryptic ritual.
The 3-word fix
- Write for outsiders. Pretend the reader is a smart new hire who’s never seen a SAR or a ristretto.
Coffee-menu test
- Read any policy aloud. If you can’t explain it to a junior teller in one breath, scrap the jargon.
Example rewrite
- Before: “Initiate CDD refresh cycle upon triggering of risk-based EDD thresholds under Regulation 4.3.”
- After: “Customer sends $50k from a new country? Ask for the source of funds today AND RE-ASSESS CUSTOMER RISK.”
Bottom line
- Your staff aren’t compliance PhDs.
- Your policies aren’t regulatory art.
- Keep it simple, or the crooks will exploit the confusion.
- Next time you draft a rule, ask: “Would this fit on a Post-it?” If not, hit delete and try again.
💸 One alert. One click. One safer bank.
Save this post. Share it with the person who still says “predicate offence” in meetings.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.