The three global financial centers - New York, London and Hong Kong - may vary considerably in terms of their strategic focus, but there is a high degree of commonality to the principles of regulation for depository institutions across all three jurisdictions.
But as any seasoned compliance officer will tell you, common principles don't necessarily mean common implementation or enforcement. What may seem like small nuances among the regulatory regimes of different jurisdictions can be minefields for an institution trying to establish and maintain an effective, global compliance program. This is certainly true in the case of compliance with anti-money laundering (AML) regulations.
A number of nuances exist in the way AML requirements apply across the United States, the United Kingdom and Hong Kong. This paper examines four areas: regulatory examination and enforcement, correspondent banking, information sharing, and AML technology. It also considers the implications of these differences for financial institutions seeking to implement a global AML program and provides advice on how firms can more efficiently implement a compliant AML program that is cost-effective and provides more value to the business.