For LFIs operating in an international context, FATF Recommendation 18 recommends that financial groups are required to implement group-wide AML/CFT programs applicable to foreign branches and majority-owned subsidiaries. Recent major enforcement actions taken by supervisors in key jurisdictions have highlighted the need to ensure that systems and controls are aligned across a financial group and that foreign branches and majority-owned subsidiaries align AML/CFT measures with a financial group’s home country requirements. As a result, LFIs have implemented global AML/CFT policies that outline a group risk appetite and are managed in each jurisdiction to align to local regulatory or legislative requirements. To support alignment of controls, LFIs operating across jurisdictions may seek to leverage the same control solutions for key processes, such as customer screening or transaction monitoring, though there may be different rules for different jurisdictions. For example, if the LFI operates in an economy which is known to be more cash-based than another, the cash trigger rules in transaction monitoring may vary appropriately. Centralized controls with operational centers of excellence also provide a means of ensuring alignment across the group around systems and controls.