A
substantial number of compliance officers (about 44 per cent) lack confidence
in the anti-money laundering (AML) programs of their organizations, according
to a new report
That’s
an interesting finding since compliance officers are ultimately responsible for
compliance of the whole organization in their role as MLRO. The pace and
complexity of changes are mentioned as causes as well as insufficient clarity
of regulations. Investments in AML programs have gone up and are expected to
increase also because of ongoing technological innovations.
The
article quotes: Nadim
Najjar, managing director, Middle East and North Africa, Thomson Reuters: “The
business of compliance, which in the past was seen by many as a mere tick box
exercise, has become incredibly dynamic. It has evolved into a critical,
demanding role that challenges executives to stay up-to-date and conversant
with regional and global regulatory change and information.”
All the
reasons make sense and we see many of our clients working hard to improve their
AML/CFT policies, processes and procedures. What is not mentioned – and is
often still not sufficiently recognized – is that interpreting regulations into
policies is only the beginning of the implementation of an AML/CFT Program.
Implementing
policies in all operational areas of a financial institution would need to
cover branches, trade finance departments, customer service teams, relationship
managers and transaction processing units. Where the compliance function sits
in the 2nd line of defense, a lot of heavy lifting in daily
operation sits in the 1st line of defense.
That’s
exactly what we focus on.
