82. Many banking groups engage in securities and insurance businesses. The application of ML/FT risk management controls in mixed financial groups poses additional issues that may not be present for deposit-taking and lending operations. Mixed groups should have the ability to monitor and share information on the identity of customers and their transaction and account activities across the entire group, and be alert to customers that use their services in different sectors, as described in paragraph 79 above.

83. Differences in the nature of activities and patterns of relationships between banks and customers in each sector may require or justify variations in the AML/CFT requirements imposed on each sector. The group should be alert to these differences when cross-selling products and services to customers from different business arms, and the appropriate AML/CFT requirements for the relevant sectors should be applied.