Kevin Shepherd published "The Gatekeeper Initiative and the Risk-Based Approach to Client Due Diligence" in the April 2012 issue of The Review of Banking & Financial Services. This article is one of the first to appear in a national publication highlighting and analyzing the changes made to the 40 Recommendations by the Paris-based Financial Action Task Force in February 2012. The 40 Recommendations are the international counter-measures against money laundering covering the criminal justice system and law enforcement, the financial system and its regulation, and international co-operation.
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