2019 was the year of clarifying guidance from law enforcement, regulators, and anti-financial crime organizations, even if the effects of new expectations haven’t quite appeared in the form of increased enforcement actions. Nonetheless, it is quite likely that the punitive tail of non-compliance may start to manifest in 2020 and beyond.
Failing to have a proper roadmap or misunderstanding the rules of the road will likely serve as poor defenses against regulatory and legal inquiry.
https://www.riskscreen.com/kyc360/article/the-financial-crime-compliance-pathway-is-clear-in-2020