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AML Programs Operating in a Global Environment

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In today's complex financial environment, tailoring global AML programs to meet both global and local requirements is essential for firms operating internationally. This discussion focuses on managing cultural differences, ensuring compliance with jurisdictional requirements, and addressing evolving enforcement trends related to insider trading and anti-corruption. Key strategies include effective surveillance design, staff training on suspicious activity awareness, and adapting to local filing obligations, particularly in Asia. Understanding the landscape of sanctions and the implications for global clients is crucial for maintaining compliance and safeguarding business integrity.

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AML Programs Operating in a Global Environment

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  1. AML Programs Operating in a Global Environment Patty O’Connor Pan Asia Head, Compliance Surveillance Strategy Group Goldman Sachs

  2. Tailoring Global Programs Global KYC Programs • Global requirements vs. local requirements • Country-by-country analysis • Effectively managing the cultural differences • Lack of transparency Sanction Screening Programs • Local Jurisdictional Requirements must be met • OFAC/UK Sanction Programs – touch every aspect of FIs business

  3. Enforcement Trends and Implications Increased criminal enforcement • Insider dealing/Market Manipulation • Focus on international or offshore clients • Recent U.S. insider trading case - kept profits small to stay under radar • FCPA and Asia Anti-Corruption efforts • China - focus on “bribe givers” Implications for Firms • Surveillance design and constant refinement • i.e., identify patterns, capture smaller trading profits • Connecting the dots • Global clients mean global cooperation • Investigation and filing obligations in multiple jurisdictions • Filing obligations in Asian jurisdictions can vary greatly • Training employees – Suspicious Activity Awareness and Anti-Bribery • Effective Anti-Bribery Programs

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