HomeNews (Not Legal) Advice from the AML & Financial Crimes Congress 2022
(Not Legal) Advice from the AML & Financial Crimes Congress 2022
Friday 10 June 2022
A quick snapshot of what you may have missed if you weren't able to the attend our AML & Financial Crimes Congress 2022:
There continues to be disconnect between risk assessments and product offering.
Do not overcomplicate the risk assessment.
Flawed risk assessment methodologies can unfortunate consequences later.
Ensure AML & financial programs from third party providers actually fit your business model.
Ensure your transaction monitoring program continues to be relevant to your product offerings and business strategy—Review this often!
Only use resources to monitor things that you offer.
Ensure risk owners ( the business) have accountability of the financial risks as well as non-financial risks!
Try not to create too much friction for customers when building or reviewing your program.
Document everything!
Welfare fraud and identity fraud are some of the key areas from the regulator.
Plan for the key person risk in in this time of the ‘great attrition.’
Make sure that you understand the nuances and regulatory expectations around know your customer, customer due diligence and enhanced customer due diligence.
The annual compliance report to Australian Transactions Reports and Analysis Centre (AUSTRAC) should be an enterprise-wide affair based all of the above!
Reporting entities should not only be considering the evolving sanction regime but countersanctions from sanctioned states.
In sanctions also look out the attempts to sidestep the sanctions by mislabelling, mixing commodities, third party relationships that might have been sanctioned yet.
Do scenario mapping!
Continue to document everything!
Be aware of requirements around Applicable Customer Identification Procedures (ACIP ) when it comes to reliance and the case-by-case basis.
Most importantly keep an ear to the ground for the AML & Financial Congress 2022 debrief Podcast where we will touch on some of the key themes of the event!