Best practices in AML: Shelter now from future tremors
By Frank Cummings, CEO of AML Partners
Tremors from the quake that was ‘the Panama Papers’ will no doubt be felt for years by financial institutions and their AML Compliance teams. Various regulators around the world are strategizing about their responses to secrets revealed in the leak, and that surely means new subpoenas and a bright light on institutions’ risk analyses applied to Politically Exposed Persons (PEPs). In fact, you can expect every PEP to be high risk going forward.
A New York Times report yesterday described new moves by New York State’s regulatory authority to request information related to the Panama Papers from some of the largest banks, a move that builds upon requests last month for data such as telephone records, other communications, and whether and what internal investigations banks are conducting.
We expect this to be the tip of the iceberg. And Monday’s unrestricted online publishing of the leaked documents may add to the momentum and the global public’s expectation for governmental follow-through. Expect subpoenas. Expect new expectations for transparency, especially related to UBOs. Expect scrutiny.
It’s been interesting to see some of the PEPs implicated and some of the strategies of doing business with the intent to evade scrutiny and hide assets. A lot of these are longstanding strategies that have been concocted by lawyers and facilitated by governments and politicians looking the other way—and often profiting themselves.
Unfortunately, AML Compliance departments—whether they had any involvement or not–will bear the brunt of the fallout of the Panama Papers. But financial institutions can quake-proof themselves—by adopting a Risk-based Approach and the right AML software solutions that facilitate high-quality CDD and ongoing due diligence. The highest-quality digitized CDD provides up-front assessments of risk–including identification and relationships among UBOs and PEPs—and then should flow into your monitoring and flagging of risk throughout the life of the customer relationship—what I call the “Legitimacy Lifecycle” of a customer relationship.
Our solution here at AML Partners is SURETY Eco, a fully integrated AML ecosystem. We have been working for years on AML Compliance solutions that help inoculate our customers against regulatory action and dangerous risk—by embracing the highest quality CDD, by the integration of that comprehensive and digitized CDD knowledge into transaction monitoring and sanctions-screening operations, and by embedding full digital audits into the data record. No funny business. No paper file folders. No panic about who knew what and when. And no undue stress when examiners arrive.
These are tough times for financial institutions and their Compliance teams—not only are they expected to operate their core business but they are pressed by governments and the public to be de facto agents of law enforcement regarding money laundering and terror financing. But these are also great times in terms of amazing technology solutions that are both effective and efficient—and that are configurable in-house with no ridiculous consulting or programming contracts required. Institutions that are not reaching out to embrace these software solutions are courting the quake—and the endless tremors that follow.
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