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Anti-Money Laundering

2013 Global Ethics Summit. Anti-Money Laundering. March 5, 2013. Risk Based Approach to AML.

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Anti-Money Laundering

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  1. 2013 Global Ethics Summit Anti-Money Laundering March 5, 2013

  2. Risk Based Approach to AML • Similar to FCPA compliance, AML compliance should focus on a risk-based approach. In fact, much can be learned from FCPA compliance when developing or improving an AML program and vice-versa. In fact, because of relative maturity of AML laws, FCPA programs can often learn from risk-based programs developed to comply with AML. • It is impossible to be 100% prepared to handle AML, and in the eyes of regulators there will often be an issue that was overlooked by compliance professionals. Compliance officers must be prepared to discuss with government how they came to the decisions they came to, how they decided on the risks that they identified as the most critical, and how they decided to address the risks in the way that they did. Investigators will ask direct and pointed questions to get this information

  3. AML vs. FCPA • When looking at AML risk based approach, most companies look outward at clients bringing money in.  From corruption you’re looking inward and addressing how internal groups could be facilitating bribes.  Discussion around the differences there. • What can anti-corruption professionals learn from AML folks?  The regulatory environment for AML is much more mature and has gone "through the ringer" more than it has for corruption, despite the recent enforcement of FCPA.  FCPA gets a lot of attention but what does it mean to be best practiced and have a good program?  AML has been enforced aggressively since 2002 and so is more mature.  How do the policies and procedures differ? • Know how certain countries/regions rank on a risk scale for both AML and FCPA, and don‘t expect each region to have similar risk level in both categories.

  4. Best Practices in AML • AML is a sophisticated compliance/risk area, however issues continue to arise around AML violations – see HSBC fines/negative publicity from recent issues – what are best practices companies are using today to continue to stay ahead of new regulations and enforcement in the AML arena?

  5. Not Just for Financial Institutions • Today it could be more difficult for banks to violate AML laws than other industries because of extensive bank oversight which has gone on and matured over a decade or more.  Other industries need to be on top of AML issues as well, as they could be more susceptible as a result of less oversight than banking industry.  What should companies of all industries do to ensure they are safely mitigating AML risk?

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