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Warren Dickins, Financial Crime Officer at GE Capital International shed light on the biggest AML/CTF challenges for multi-jurisdictional organisations:
If you are working in a financial crime role today in an organisation that operates in more than one jurisdiction, it will be no surprise to you that everywhere you look there are different challenges.
Every additional jurisdiction where you are open for business increases the complexity.
So, where do you focus first?
Do all stakeholders deserve the same attention?
Are all your risks created equally?
How can you be certain you know all of your risks?
Consider a few of the challenges that arise because you are multi-jurisdictional:
THE BASICS:
International often means different time zones, different languages, and different laws.
It means that meeting times with your business won’t be suitable in all jurisdictions and multiple meetings may be needed. It means that a task like building an inventory of laws for your compliance plan becomes a significant challenge and establishing global centres of excellence are challenged by other laws like data privacy. It means that when you develop a training program, it’s required in many languages and you may need to create a program that accounts for the views or requirements of multiple regulators.
REGULATORY IMPACT:
Even if all regulators had the same approach, you would still have to manage multiple relationships, possibly have Regulator reviews across different places at the same time, and need to keep HQ and local management informed in an appropriate order.
In reality, the regulatory approach is not always consistent.
In each of your localities you need to focus on what is important to that Regulator, and in addition each business will have the added layer of influence from your home Regulator.
If one of your Regulators is actively pursuing action against financial institutions in your home jurisdiction, or other jurisdictions where you have business, does that influence your approach?
CHANGING ENVIRONMENT:
New risks seem to appear on a daily basis.
Over the past few years the global political and social environment has changed regularly, conflicts continue to break out, and by the time your latest jurisdiction risk assessment is assessed via committees and Boards, the information is likely to be out of date.
How are you managing your exposure to the current Ukraine/Russia conflict? A business based only in Australia may have limited exposure, however if your businesses are based in Europe it’s likely you will have daily decisions to make about allowing payments to proceed or how to manage impacted customers. Do you know which of your customers derive income or have ownership in that region?
COMPLIANCE OR RISK MANAGEMENT:
AML/CTF requires skills in both.
Your organisation needs a robust framework and consistent processes that make it easy for your employees to follow, and for you to show your stakeholders that you are compliant. However, you must retain flexibility to allow for risk based decisions to be made in a timely manner when new issues arise and new opportunities are presented.
How much flexibility do you allow your overseas businesses? How much investment do you put into building the skills of your resources both at HQ level and in each jurisdiction? How well do you share information about your successes and issues?
Managing your risk wisely on a global scale means you need the right people managing the risk in each locality, with flexible support and guidance from HQ, and the culture of the compliance and risk team is not out of alignment to that of the sales and marketing teams.
How does your organisation stack up?
Warren will be speaking at the upcoming Anti-Money Laundering Summit on 11th and 12th September in Sydney, on the topic “Dealing with the challenges of AML/CTF for an institution with a global footprint”.
Join Warren and many other industry experts at this highly anticipated event. For more information about the event agenda and to register, please visit the Anti-Money Laundering Summit website.
