analysis: aml
IBS Journal May 2015
a weak area for firms,’ says Gary Wilson, consultant at risk specialist, CCL Compli- ance. There are a couple of years before the regulations will need to be adopted and it is uncertain how often the data will need to be updated, how it will be checked, and how much weight will need to be placed on it, he says.
Under the Directive, the EU will also
produce a blacklist of countries that are deemed to be not up to the mark for AML. ‘The major usual suspects will be on there,’ predicts Wilson. However, it might well meet similar resistance to a list produced by the UK regulator, the Financial Conduct Authority (FCA), which was challenged and quietly dropped. He expects the new list to be used to put pressure on some countries and to be taken into account by firms when considering overall risks but, again, it is not clear how much weight will need to be given to it.
The main question is now, what can
be done to put a bank’s house in order? The current situation varies a lot from one institution to another, says Wilson. He believes that a full risk assessment is the starting point for moving to best practice. ‘There can no longer be the attitude, how little can we get away with?’ He feels the assessments should look at four areas comprising products and services; types of clients; delivery methods (face-to-face or non-face-to-face); and geographic risks. For the latter, ‘the EU blacklist should be very helpful because firms do still get that wrong’. Louise Main, a senior consultant at
Capco, agrees that a sound enterprise risk assessment is a building block of good compliance. ‘Even something as basic as policies and procedures can differ mas- sively across business lines and locations,’ she says. Sometimes the differences are
sensible, related to different levels of risk and regulations, but often they are not. The implementation of technology
is often an outcome of the assessments, says Main, but a lot of the issues are about people and culture. AML needs to be embedded in the organisation, not just the responsibility of the risk and compliance teams. ‘Often in companies, people are not living and breathing the regulations,’ she says. There is no easy answer to the cultural challenge, but it is to do with training, awareness, proper documentation, and clear and understood procedures and rules, including those related to escalation. In terms of technology, the knack, says
David Deane, group head of client and data services at Deutsche Bank, will be ‘to heav- ily automate as much as we can in the low risk space so we can focus on the high risk’. He was speaking at Swift’s recent London Business Forum and the fact that there was
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56
