64. Consolidated risk management means establishing and administering a process to coordinate and apply policies and procedures on a group-wide basis, thereby implementing a consistent and comprehensive baseline for managing the bank's risks across its international operations. Policies and procedures should be designed not merely to comply strictly with all relevant laws and regulations, but more broadly to identify, monitor and mitigate group-wide risks. Every effort should be made to ensure that the group's ability to obtain and review information in accordance with its global AML/CFT policies and procedures is not impaired as a result of modifications to local policies or procedures necessitated by local legal requirements. In this regard, a bank should have robust information-sharing among the head office and all of its branches and subsidiaries. Where the minimum regulatory or legal requirements of the home and host countries differ, offices in host jurisdictions should apply the higher standard of the two.

65. Furthermore, according to FATF Standards, [See Interpretative Note to recommendation 18 (Internal controls and foreign branches and subsidiaries) in the FATF Standards.] if the host country does not permit the proper implementation of those standards, the chief AML/CFT officer should inform the home supervisors. Additional measures should be considered, including, as appropriate, the financial group closing its operations in the host country.