Given the increasing regulatory scrutiny related to AML issues and complex challenges faced by financial services organisations in that regard, institutions are realising the importance of implementing and maintaining a robust AML program.
In addition, companies are realising the importance of implementing a risk-based Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Compliance Program that can be applied across diverse business lines. However, evaluating the money laundering risks in an organisation and the tools and techniques available for mitigating these risks can present a significant challenge.
The core members of Protiviti’s AML Practice are former financial institution regulators, financial institution compliance officers, fraud and forensic specialists, technology experts, and individuals with hands-on experience working in financial institutions of all types. They have considerable experience advising institutions of all types on the design and implementation of their AML/CFT Compliance Programs, conducting independent tests of AML/CFT Compliance Program effectiveness and conducting money laundering investigations.
Protiviti Perspective provided by Carol Beaumier, Executive Vice-President and Managing Director Regulatory Compliance Practice
We assist organisations with the development, implementation and delivery of AML/CFT training that is customised to reflect an organisation's primary business activities, customer profile, current AML/CFT knowledge base and internal procedures.
Design and Implementation of AML/CFT Risk Assessments
An effective and complete AML/CFT Compliance Program considers the business and customer profile of an institution. We can review the institution’s business, customers and transactions to identify areas with high potential for exposure to money laundering and/or OFAC violations.
Program Development, Implementation and Review
AML/CFT risk management requires companies to identify, measure, control and monitor money laundering risk effectively. Our professionals have assisted and continue to assist a variety of clients with developing and implementing comprehensive AML/CFT Compliance Programs that address the latest regulatory and industry expectations and the company’s own unique money laundering risk. This includes documentation of the AML/CFT Compliance Program in the form of customised policies and procedures.
AML/CFT System Vendor Selection and Utilisation
We assist in the selection of appropriate technology tools to support ongoing AML/CFT and OFAC monitoring. This includes current and future requirements, vendor review and assessment scorecarding, project planning and management, implementation support, system tuning and system validation.
Model Assessments and Data Validation for AML/CFT Systems
We perform independent assessments of AML/CFT and sanctions-related models, which include assessment of an institution’s model governance, evaluation and tuning of scenario and threshold settings, and validation of data sourced for the models.
OFAC Sanctions Compliance Program Design and Reviews
We work with a variety of organisations to review existing OFAC Sanctions Compliance Programs and make recommendations for enhancements. We also assist in the development, implementation and documentation of an effective OFAC Sanctions Compliance Program.
Money Laundering Investigations
Money laundering schemes are becoming increasingly sophisticated and complex. Our professionals identify the flow of funds from originator to ultimate beneficiary and identify the parties and the financial institutions involved. We identify the types of instruments used in the scheme(s), determine the amount of funds involved, and identify relationships between related parties. We trace assets through the financial system and assist with their ultimate recovery.
Independent Testing of AML Programs
We perform independent testing of existing AML Programs, including a review of written AML/CFT policies and procedures, the AML/CFT training program, and AML/CFT-related technology reviews. We also perform selected transaction testing and provide recommendations for enhancements.
Should your Organisation become the subject of an enforcement action, we can assist you with identifying the root cause and magnitude of the issue, and the improvements necessary to prevent recurrence; negotiating regulatory agreements; developing and implementing corrective action plans; and liaising with regulatory agencies and/or outside counsel.
Some key changes from this directive include:
Robotics is replicating the human behavior. It is about pieces of software interacting with the enterprise system that we use these days in a way similar to how people interact with each other.
The AML measures remain in place but the banks are also affected by GDPR. So financial institutions will need to document the legal basis for collecting and processing personal data of their customers for AML compliance.
Since 2013, regulators have imposed over 10 billion $ fines to institutions for failure in meeting the anti-money laundering requirements. A major reason for this is the inadequate KYC records that they hold on their customers.