Transparency of the Credit Institution’s Internal Control System as a Principle of Legal Regulation of Anti-Money Laundering Mechanisms

This article delves into the assessment of substantive and procedural requisites of credit institutions’ internal control systems aimed at guaranteeing the combat against money laundering and other forms of criminal conduct encompassed by Russian anti-money laundering (AML) legislation. An analysis of the information policy of credit institutions, acting as subjects of financial monitoring, reveals a deficiency in the transparency of internal control programs. This opacity hinders their usage as tools for fostering ethical business conduct in the financial market, preventing suspicious transactions, and potentially fostering unfair (mala fide) practices by credit institutions themselves. The study proposes improvement to the credit institution’s internal control system as a fundamental AML measure. It posits that the implementation of AML requirements by credit institutions should be accompanied by a transparent information policy, constituting an interactive visualization of the internal control system. This improved transparency is crucial for bolstering the effectiveness and integrity of the AML framework.