Guide: Le défi des Personnes Politiquement Exposées (PPE)
In order to monitor internal anti-money laundering policies and comply with important regulations, banks, credit unions and similar financial institutions are required to appoint an anti-money laundering compliance officer. silver.
As part of the fight against financial crime, governments around the world require their financial institutions to implement anti-money laundering compliance programs. In the United States, for example, the Bank Secrecy Act (BSA), passed in 1970, was amended by numerous subsequent laws, including the Patriot Act. In practice, this means that US financial institutions must navigate an increasingly complex BSA compliance landscape, often resulting in significant administrative burden and serious legal consequences. To ensure compliance, it is often necessary to appoint an anti-money laundering compliance officer: a primary person responsible for overseeing the effective development and implementation of the anti-money laundering program of their institution.
Senior management of a financial institution should consider the following factors when choosing an anti-money laundering compliance officer.
What does the Anti-Money Laundering Compliance Officer do?
Although all employees should be aware of their company ‘s anti-money laundering policy , the compliance officer is responsible for its implementation at the institutional level. The main professional objective of an anti-money laundering compliance officer is to focus on the internal systems and controls that their institution puts in place to help them detect, monitor and report the activities of money laundering to the authorities. Their job is to ensure that their institution is not exposed to criminal risk and does not unwittingly facilitate financial crime.
Of course, the finer details of an AML officer’s responsibilities vary from country to country. In the US, for example, a BSA-AML compliance officer would liaise with the Financial Crimes Enforcement Network (FinCen), while a UK anti-money laundering officer would report to the National Crime Agency (NCA). Generally speaking, however, anti-money laundering policies and strategies are often mirrored across jurisdictions, and the practical duties of an anti-money laundering compliance officer will include the following:
- Assist in the development, implementation and maintenance of an anti-money laundering program within their institution.
- Ensure compliance with applicable anti-money laundering regulations and other relevant legislation (eg USA Patriot Act).
- Develop and maintain a risk assessment framework for products and services, customers and customers, and other money laundering issues.
- Maintain and maintain high-risk customer records and report suspicious activity to authorities.
- Organize and implement third-party inspections and audits and make recommendations for compliance based on their findings.
- Briefing and reporting to senior management on matters relating to internal anti-money laundering compliance policies and procedures.
- Oversee and implement an ongoing anti-money laundering training program for other employees.
Appointment of an Anti-Money Laundering Compliance Officer
Given the importance of an institution’s anti-money laundering compliance program, a compliance officer must have in-depth knowledge and skills in all areas of financial policy and procedures, as well as in methods of financial crime. At the time of appointment, it is essential that senior management choose a candidate who not only has the ability and expertise to perform their duties effectively, but who meets the unique professional needs of their institution.
The ability and dedication of an AML Compliance Officer will shape your AML program and reflect your institution’s commitment to fighting financial crime. With this in mind, when appointing an anti-money laundering officer, the following factors should influence your decision:
Time and focus
Consider the administrative burden your AML compliance officer will face within the institution – and ensure they have the time and resources to carry out their duties. Larger organizations, which have a much heavier administrative burden, will likely need to supplement a full-time employee who will focus solely on AML compliance, but smaller institutions might be able to supplement these duties part-time.
Expertise and training
An anti-money laundering officer should have considerable experience and understanding of the financial and regulatory landscape, as well as relevant risk management strategies . This knowledge and expertise should go beyond anti-money laundering systems and internal controls and extend to the methods of money laundering (and associated criminal activities), as well as the potential risk posed by certain clients and customers.
AML compliance is an ever-changing field, so your compliance officer’s expertise should reflect the current regulatory climate. With this in mind, there are a variety of industry bodies that offer AML certification and training .
Authority and Trust
Given the frequent legal implications of AML compliance, it is essential that your compliance officer has sufficient authority to ensure that they can effectively carry out their role and responsibilities. Not only do anti-money laundering officers monitor and process a variety of sensitive financial data, but they must also interact regularly with senior management and the board of directors, as well as financial authorities. Ideally, an anti-money laundering officer should be an administrator-level employee with the experience and confidence to engage in all aspects of their professional environment.
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Publié initialement octobre 31, 2019, mis à jourjanvier 25, 2023
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