Modernising the Fight Against Financial Crime – Part 3 – by John Cusack

Having attended the FATF Consultative Forum on the 6-7th May, 2019, I was invited to present on “the latest trends / priorities in the Public and Private Sectors on AMLCTF.” Here is a brief summary of my presentation, which is based on work progressed within the Wolfsberg Group.

Modernising the Fight against Financial Crime

As we seek to modernise the fight against financial crime, we need to put “effectiveness” ever more at the centre of what we do. For FI’s technical compliance assessments are extremely challenging but also fail to measure contribution or effectiveness. In order to support improved effectiveness the areas that need additional attention include (see chart below):

Whilst there is no silver bullet, real progress is dependent upon a common understanding of what outcomes we want to achieve and what then should be the priorities. Whilst it seems each of us looks at outcomes and priorities through the prism of our own realities, we need to find a common purpose and we don’t have time to commission a board of enquiry. One idea is why not take the 11 Immediate outcomes published by FATF, and apply these to all stakeholders or those expected or required to contribute. For example for FI’s in the regulated sector, we could be asking how we contribute and or conceivably how we could contribute even more and what that would look like and how would we measure it. If successful, we would have a much improved model to assess FI’s and their contributions in a way that measuring strict technical compliance does not. Exploring this approach could boost Country results on effectiveness, by incentivising positive contributions which is the purpose of the exercise.

This idea and others that target improved effectiveness were at the core of discussions at the annual Wolfsberg Forum held on 22nd-24th May 2019.

For more details on Modernising the fight against financial crime see Part 1 & Part 2.

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