To guard against acquisition or control of a financial institution by money launderers or their associates, what should supervisory agencies require?

Surety bonds and cash deposits address financial liability and solvency concerns, not the criminal fitness of prospective owners, so they do not prevent a money launderer from gaining control.

Compliance programs govern ongoing operational behavior and do not constitute a gatekeeping mechanism to screen out unsuitable individuals at the point of ownership acquisition.

Prior finance experience is not a reliable indicator of criminal intent and would not specifically identify or exclude money launderers or their associates from ownership.

Thorough due diligence on prospective owners - encompassing background checks, integrity assessments, and source-of-wealth verification - is the direct mechanism for identifying and rejecting individuals with criminal associations before they can acquire or control a financial institution. This aligns with FATF guidance on fit-and-proper requirements for financial institution ownership.