ACFCS Conference

AML and the New World Order

As technology continues to advance rapidly and new, innovative forms of currency such as Bitcoin arise, the landscape of counter threat finance and anti-money laundering is constantly changing to meet new demands. During a conference panel on anti-money laundering in the new world order, hosted by the Association for Certified Financial Crimes Specialists (ACFCS), senior compliance specialists from private banks, money service businesses (MSBs) and the intelligence community discussed the ways new standards, technologies and risks are shaping the field of AML. Today, emerging and advancing risks to consumers essentially require financial institutions to protect consumers from themselves. For example, the growing use and validity of virtual currencies such as Bitcoin are an integral part of the new world order.
On a broader scale, financial institutions can implement active filters for things such as consecutive round amount charges or charges during non-operational hours, to Financial Intelligence Units (FIUs) and Suspicious Activity Reports (SARs) by utilizing a piece of behavior, an exchange of data or some information in to combat against these threats and actually exploit criminal networks involved in threat finance and other illicit activities. Evaluating your current active SARs program in order to maintain a consolidated approach as well as be able to pinpoint discerning trends from the reports is another critical measure in keeping up with the changing environment.

What are the emerging risks?
Often times, they are operational risks such as weak supply chain channels. Consistent transaction testing, where “risk-friendly” transaction types are steadily tested for vulnerabilities are essential for recognizing operational risks before they spread and advance. An increase in government oversight, complex new laws and risks and faulty discourse amongst institutions on a global scale make AML a greater danger than ever before. Today, money laundering and threat finance plays a key component in virtually all crimes worldwide, as new technologies make laundering money across the globe easier than ever. Thus, risk mitigation and comprehension of emerging and high-risk products; regions and consumer markets are vital for financial institutions to stay up to speed with these evolving threats.

Beneficial Ownership
Beneficial ownership requires companies to recognize what information is needed and what system enhancements are required to attain that information. How are you collecting customer information? This question could involve something as simple as recognizing if your applications and forms have enough lines for relevant information. What is your overall AML policy? What enhancements are you making to your programs? Regular evaluation and updating of policies is essential in keeping up with new threats.

Breaking Down Silos
How are you communicating within the organization and who is responsible for communicating? Breakdowns in communication can have greater negative implications and create much vulnerability for a company. Thus, it is important to maintain a clear idea of the broader picture in order to insure that data sharing between departments is efficiently occurring and weak points are being adequately addressed.