(Not Legal) Advice from the AML & Financial Crimes Congress 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!