In the work
we do with financial institutions we use concepts that are familiar to most
you. The 3 lines of defense model, taking a risk based approach, defining a
risk appetite and assessing an organization against this are a few key examples
of these.
That’s an
approach that goes well with our fellow AML/CFT practitioners and compliance
officers in general. If we talk to the first line of defense though – whether it
be sales staff, relationship managers, the trade finance department, tellers,
payment processing staff or support staff – we often find some skepticism when
we take this approach.
In the
front line there are 2 things we notice. First there is a clear and explicit
desire to know ‘what is allowed’. As a specialist or advisor we’re asked to
give direction and guidance on client onboarding, filtering treshholds, documentation
requirements and more. Understandable but what is needed is that the organization
takes an approach in line with its own policies and guidelines. An advisor can
share best practices but every organization is different.
Secondly we
notice that the majority of staff still believes that compliance costs money
and that the organization should do the minimal and not more. Even though most management
and staff are aware that non-compliance is expensive there’s little desire to
do more than just ‘tick the box’.
Just
curious if this is something that others see as well, we welcome your thoughts
and reactions.
Rolf
E: Rolf@i-KYC.com
W: www.i-kyc.com
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