things to help keep MLROS focussed and ahead of the

game

5

1Where are you? - Anti-terrorist funding

training and red flag indicators for staff.

With the rising menace of ISIL funding that is likely now to be lapping our shores via professional money launderers and Syria banks in Damascus, we must be more vigilant than ever to detecting and disrupting this finance.

Reliance on the sanctions lists is not sufficient because as we know from the report provided by QC David Anderson, the terrorists are simply not being listed by name!

2A date for your diary – 13th July

‘Judgement day’ for Arab Bank in the US courts.We will learn just how much the US courts will award to

the victims and the bereaved and aggrieved families of Hamas terrorist atrocities after Arab Bank became the first bank to be found criminally liable under the US Anti-Terrorism Act.

Expect a big number and a rush for assurance from the Boards of firms anxious to avoid a similar liability from the inevitable surge in litigation that has started in the US and which will accelerate during 2015 and beyond!

3Resource, resource, resource!

It is critical that you are appropriately resourced and supported to meet the ever increasing demands and expectations being placed on money laundering teams and nominated officers.

In November 2014 the FCA reported that in 33% of firms visited as part of their review of how small banks are managing risks, there was inadequate resource.

In the notice that was published subsequently by the FCA of enforcement action taken against the Bank of Beirut and the senior managers, the lack of resource was again indicated as being suggested as a factor for non-compliance with remedial action plan requirements. Make the case and keep pushing.

4Fourth EU Money Laundering Directive – be

prepared.

Subject to any final and unexpected changes that may be made by the European Parliament, we now have sight of the final text.

Firms should be benchmarking their policies and procedures to these requirements and enabling the changes that must be made ahead of the new UK money laundering regulations that will implement these regulations.

It is expected that the new UK regulations will be implemented well within the two years allowed for such a change, as the UK prepares for the fourth mutual evaluation by FATF.

5AML/CFT Risk Assessment - A little spring

cleaning may be seasonal and may be appropriate!

Is it really the case that 50% of firms visited by the FCA in their review of small banks were unable to show to the regulator their risk assessment?

This surprising and embarrassing statistic implies that there is still some work to be done for some firms who have not recorded their plans, whilst those that have them should be dusting them down and conducting regular reviews and updates to demonstrate that this is a ‘living and breathing’ assessment, rather than a one off event.

Find out more about

professional qualifications and training in AML, governance, risk and compliance

and financial crime prevention

at www.int-comp.com