Some key takeaways from the French banking regulator's €1 million fine on SocGen's BaaS company Treezor: - Out of a sample of 30,000 clients, 99.8% were assigned a low or "moderately low" risk, leaving just 28 clients as medium or high-risk. - The first automated KYC platform Treezor used would flag clients exclusively based off a politically exposed person (PEP) check; no litigation, regulatory, sanctions, or other checks. The company later acquired SocGen's group-wide KYC platform, but implementation was patchy and at times Treezor compliance teams were using both platforms in parallel. - Material information easily identifiable through EDD was missed in a number of KYC cases picked for review at random by the regulator; three of the cases had not picked up that the respective clients had previously been given prison sentences. Treezor's legal team responded that, in the first case, the media coverage reporting on the prison sentence could not have been used to inform a client risk rating since media report was often unreliable; in the two other cases, it argued that the sentences were historical and as such could not affect the clients' risk ratings. There is no doubt that Treezor should have used a more capable #KYC tool, and complemented the KYC tool with human-driven analysis and complementary research. However, it is debatable whether a €1 million fine and a formal reprimand for the largest BaaS company in France will be enough of a deterrent for companies in similar situations to spend the money and time required to establish best-in-class AML/CFT processes. Read our full article here: https://lnkd.in/e8s6sH_3
Pierre le Jeune d'Allegeershecque’s Post
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How can privatization and public private partnerships help combat financial crime? What is the role of regulatory compliance in increasing society's trust in financial institutions? The answers are known. The challenge is for all citizens to learn them. #aml #ctf #regulatorycompliance #financialinstitutions #financialcrime #socialtrust
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Ever wondered why money launderers always stay one step ahead of regulations? Let’s explore three main risk factors. 1. Money launderers exploit weaknesses in the financial system. ↳ They find loopholes in the AML processes of financial institutions. ↳ They create shell companies to obscure the origins of funds. ↳ They adapt their methods faster than regulations. 2. Sophisticated criminal organizations retain specialized professionals. ↳ Lawyers and accountants whose job is to identify loopholes in various countries. ↳ These and other professionals create a web of legitimate-looking transactions. ↳ They know how to obscure the real beneficial owners of entities. 3. Money launderers have the time and money to outsmart compliance professionals. ↳ They exploit the fact that compliance professionals are busy. ↳ They aim to hide one illegal transaction among many legitimate. ↳ They favor times when compliance departments are understaffed or on holidays. Compliance Officers: Stay alert! Stay vigilant! And keep up the great work!
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Great post from Anna Stylianou raising a critical point about how launderers manage to stay one step ahead of regulations. Hope her post reaches Compliance professionals at all levels. Here are a few additional thoughts on the three main risk factors highlighted: 1. Continuously evaluate and update AML processes to close any existing loopholes. 2. Increasing private-public partnership and international cooperation can help identify and mitigate cross-border loopholes exploited by launderers. 3. Ensuring compliance departments are adequately staffed and supported, especially during critical times (as Anna mentioned in her post) can prevent exploitation. 4. Continuous training and development of compliance professionals to keep up with evolving techniques and maintain vigilance. 5. A proactive approach in anticipating and adapting to new laundering techniques is crucial for staying ahead.
Anti-Financial Crime & AML Advisor | Board Governance | Building Compliance-by-design programs | Educating and Inspiring Compliance Teams | AML Trainer | Helping Businesses Stay Ahead of Regulatory Risks
Ever wondered why money launderers always stay one step ahead of regulations? Let’s explore three main risk factors. 1. Money launderers exploit weaknesses in the financial system. ↳ They find loopholes in the AML processes of financial institutions. ↳ They create shell companies to obscure the origins of funds. ↳ They adapt their methods faster than regulations. 2. Sophisticated criminal organizations retain specialized professionals. ↳ Lawyers and accountants whose job is to identify loopholes in various countries. ↳ These and other professionals create a web of legitimate-looking transactions. ↳ They know how to obscure the real beneficial owners of entities. 3. Money launderers have the time and money to outsmart compliance professionals. ↳ They exploit the fact that compliance professionals are busy. ↳ They aim to hide one illegal transaction among many legitimate. ↳ They favor times when compliance departments are understaffed or on holidays. Compliance Officers: Stay alert! Stay vigilant! And keep up the great work!
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Thanks Anna. Frankly speaking, just like other fraudsters, to outsmart money launders is not a walk in the path job. Their 24/7 objective is how to get away with financial crimes unlike MLROs who in some cases have focuses on other things. Some strategies to look at includes; Techniques used by money launders keep on changing & gets sophisticated day by day hence MLROs should always be on a learning state & evolve their approaches with such changes, AML measures/ frameworks should never be static, they should continually be reviewed and aligned with regulatory changes & emerging risks. Reporting institutions should increase their investment in research, adopting new technologies & talent. Collaboration/Information sharing across institutions/AML professionals & jurisdictions should be enhanced, Lastly, AML compliance responsibility should be an entity wide responsibility rather than looking at it as a compliance function responsibility.
Anti-Financial Crime & AML Advisor | Board Governance | Building Compliance-by-design programs | Educating and Inspiring Compliance Teams | AML Trainer | Helping Businesses Stay Ahead of Regulatory Risks
Ever wondered why money launderers always stay one step ahead of regulations? Let’s explore three main risk factors. 1. Money launderers exploit weaknesses in the financial system. ↳ They find loopholes in the AML processes of financial institutions. ↳ They create shell companies to obscure the origins of funds. ↳ They adapt their methods faster than regulations. 2. Sophisticated criminal organizations retain specialized professionals. ↳ Lawyers and accountants whose job is to identify loopholes in various countries. ↳ These and other professionals create a web of legitimate-looking transactions. ↳ They know how to obscure the real beneficial owners of entities. 3. Money launderers have the time and money to outsmart compliance professionals. ↳ They exploit the fact that compliance professionals are busy. ↳ They aim to hide one illegal transaction among many legitimate. ↳ They favor times when compliance departments are understaffed or on holidays. Compliance Officers: Stay alert! Stay vigilant! And keep up the great work!
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Interesting read.
Anti-Financial Crime & AML Advisor | Board Governance | Building Compliance-by-design programs | Educating and Inspiring Compliance Teams | AML Trainer | Helping Businesses Stay Ahead of Regulatory Risks
Ever wondered why money launderers always stay one step ahead of regulations? Let’s explore three main risk factors. 1. Money launderers exploit weaknesses in the financial system. ↳ They find loopholes in the AML processes of financial institutions. ↳ They create shell companies to obscure the origins of funds. ↳ They adapt their methods faster than regulations. 2. Sophisticated criminal organizations retain specialized professionals. ↳ Lawyers and accountants whose job is to identify loopholes in various countries. ↳ These and other professionals create a web of legitimate-looking transactions. ↳ They know how to obscure the real beneficial owners of entities. 3. Money launderers have the time and money to outsmart compliance professionals. ↳ They exploit the fact that compliance professionals are busy. ↳ They aim to hide one illegal transaction among many legitimate. ↳ They favor times when compliance departments are understaffed or on holidays. Compliance Officers: Stay alert! Stay vigilant! And keep up the great work!
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Want to optimize your compliance program? Discover how tailored transaction monitoring rules can help your organization detect suspicious activity more effectively and stay ahead of financial crime. Read more: https://hubs.la/Q02_4NTD0 #AML #transactionmonitoring
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🏦 Technology is now attracting almost two-thirds of financial crime compliance budgets 🏦 As the FCA raises concerns about AML controls, the financial sector is turning to tech solutions to address these challenges. In 2023 alone, UK banks spent £38.3 billion on compliance, marking a 12% increase from the previous year. The FCA highlighted weaknesses in financial crime controls related to inadequate training, insufficient resources, and poor record-keeping, particularly as firms expand. The LexisNexis report highlights a significant shift towards technological investments, with 61.9% of compliance budgets now dedicated to tech, up from 50.9% in 2022. #Compliance #AML #Fincrime Full article 🔍 : https://lnkd.in/eE6s2VeB
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The Financial Crimes Enforcement Network (FinCEN) recently issued a notice of proposed rulemaking (NPRM) concerning the Anti Money Laundering Act of 2020 (AML Act). Stay informed and updated on the latest developments in financial regulations. #FinCEN #AMLAct #FinancialRegulations
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For those in APAC timezone that missed the kickoff to our State of Compliance webinar series, don’t worry—it's available to watch on demand. Our Regulatory Affairs team breaks down how to "Build Your AML Roadmap," focusing on upcoming financial crime trends and how your firm can prepare. Stream the full webinar here:
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