The questions in this article this article are indeed often asked by our
clients. The answers provided make sense but I’m not so sure that we can call
these true innovations… AML requires a financial institution to interpret
regulations and embed these in internal policies. That’s the easy part. The
next step is to get the rest of the organization to read and understand the
policies and to amend all SOPs to ensure the first line of defense, functions
in accordance with the policies. That’s not rocket science either but it’s a
lot of work, has wide spread implications throughout the organization and
touches on the day-to-day activities of many employees.
As the author rightfully states: taking this challenge
seriously can be done within existing budget and in our opinion and experience
(!) can actually save money. Four key points need to be taken into account:
-
Define a proper Target Operating Model so that
it’s clear who is supposed to do what across the 1st LoD;
-
Ensure there is one (!) central owner for all
operational execution of AML/CFT processes; even if AML/CFT operations is not
centralized you still need single ownership over all AML/CFT work;
-
Focus on numbers and make sure your management
information measures progress, turnaround time and effort just as well as quality
and meeting the compliance requirements;
-
Automate wherever possible.
And a final overall piece of advice; take this whole
exercise seriously and execute the change program to reach the target model
rigorously. We have proven it with various clients: you can meet AML/CFT
requirements and still operate at a cost efficient level and still be customer
friendly.
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