Applies to: Health Check
Financial crimes are occurring 24/7, 365 days a year and costs the world economy trillions of dollars. Anti-money laundering and counter-terrorism financing laws now apply to millions of organisation’s of all sizes, across a range of industry sectors and over 200 member countries of the Financial Action Task Force.
The stakes have never been higher for regulated entities to demonstrate to Boards and regulatory authorities that they have an effectively designed, implemented and maintained AML/CFT program and it is a mandatory requirement that these are subject to regular independent review.
The independent review process can be a time consuming and expensive exercise and often fails to deliver clear insights into compliance gaps or provide actionable business intelligence needed to make improvements to AML programs, with one-dimensional report outputs being of limited value to the organisation after the consultants have left for the next job.
Regulated entities need to have a robust framework for regularly monitoring the effectiveness of the AML/CFT compliance programme to assess whether it is adequate and proportionate; meaning, whether systems, procedures and controls have been designed in a way that are fit for purpose and have been implemented and are operating effectively.
The outputs of the AML/CFT programme review need to be provided back to top management and a commitment made for tracking and implementing continual improvement to address any compliance gaps identified if the organisation is to avoid material fines and penalties for non-compliance which for the global banking community alone has exceeded USD$260 billion, in less than a decade.
This infographic below shows the size of the financial crime challenge.