EU Bytes T
ime & Place Consulting recently partnered with the newly created but already world-famous company, COMPLOK. The company is led
by a superstar in AML compliance from Estonia, Mari-Liis Kurg. With that name, we obviously couldn’t help but develop a special tag-line: AML, Ask Mari-Liis. With my partners’ and my background in gambling and Mari-Liis and her team’s expertise, we knew we were a perfect fi t to create an integrated 360°-service approach to strengthen client AML capacities. In brief, the services we provide range from providing implementation tools such as staff training, to reaching out to policy decision-makers so as to defi ne sustainable legislation and standards. Here, we interview Mari-Liis for Casino
International. We talk about what the AML landscape looks like, the importance of having a good AML strategy, and the future, namely cryptocurrencies.
G. Cezanne: Hi Mari-Liis. COMPLOK provides a range of capacities, but your recent fl agship is AML/KYC/Sanctions e-learning and classroom training. Also, it is about managing business training activities and increasing compliance awareness. Why did you see this need? M.L. Kurg: Compliance culture starts from top management and it’s only followed successfully if your employees are willing to follow. Or even in the wider scope, if society is willing to follow compliance culture; so, in other words ready to comply with external laws and regulations. Training is one of the most important ways to emphasise the importance of AML/CFT efforts and to educate employees about what to do if they encounter possible money laundering. Training also acts as a crucial control measure in the mitigation of money laundering risks and is part of the company’s culture which is refl ected in everything from hiring new employees to planning strategic goals. According to EU AML Directives and other AML related laws
Glenn Cezanne introduces a new colleague from COMPLOK and invites us to Ask Mari-Liis – AML, see what we did there? Mari-Liis discusses money laundering across the sector, and the impact of crime on cryptocurrencies with Glenn
and regulations, all employees who are directly or indirectly involved in customer service processes should receive appropriate AML/CTF training. The starting point for applying an effective AML/CFT training programme is to identify the target audience. And, in the gambling sector I see a very broad applicability as well, starting from the casino fl oor staff to lottery sales points. GC: I fi nd it very important that you raise the human element, especially in light of many discussions I have had with policy- makers. There is often a notion that digital is better than human in terms of mitigating AML risks. Without going into too many details, I have to say that I don’t see this as necessarily true. The human element is extra-ordinarily important, especially when it comes to understanding customer behaviour. It is a completely different approach and requires a different skill set than analysing data. It is the same with responsible gambling. Staff are able to recognise stress, and other indicators very
24 APRIL 2021
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