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What is sufficient anti-money laundering protection?

What is sufficient anti-money laundering protection? In the wake of the Financial Services Authority fining private bank Coutts more than £8 million for anti-money laundering failures, Michael Rhodes, senior fraud consultant, SAS UK, says banks need to monitor all activity for fraud and analyse typical fraud techniques.

To ensure adequate monitoring of high-risk individuals, such as politically exposed persons (PEPs), financial institutions are obliged to show due diligence from customer acquisition through to in-life monitoring. This emphasises the importance of not only screening clients against watch-lists, but also examining the transactions of a client to detect suspicious behaviours. It is essential for banks to have sufficient anti-money laundering systems in place, particularly in the case of PEPs who are susceptible to being targeted for illegal payments.  What needs to be determined however is what exactly sufficient anti-money laundering protection is? 

Ultimately the responsibility for this monitoring falls to the money laundering reporting officer within the bank. It is up to this individual to ensure that the banks have the best possible protective systems in place to be able to identify money laundering activity.
 
In the event of PEPs attempting to hide illegal payments, there should be monitoring systems for analysing typical fraud techniques such as proxy accounts, regular smaller transactions or outright first party identity fraud. Banks need to be willing to monitor all activity; particularly the point of acquisition that can lend itself to being abused by money launderers. Failure to do so will allow illegal payments to go unnoticed and will result in the bank receiving severe penalties.
 
A key issue to overcome is ‘false positives’ in sanctions screening.  Appreciation of the varying accuracy and completeness of the supplied sanctions data sets (and PEPs for that matter), is paramount to implementing a feasible strategy that complies with FSA regulations. Ultimately, strong fuzzy matching capabilities are essential to reducing false positives, and to reduce exposure to undesirable clients. Such a system should include transaction monitoring, rules-based analysis and complex analytical modelling techniques, and should be designed so as to not inhibit new business growth, but rather fulfill the obligations as required by law.
 
Then there is the problem of the amount of data that is accrued by financial activity. This is exacerbated in the case of PEPs, who have investments scattered across the globe. On any given day there will be millions of transactions occurring within a bank. The only way that illegal activity will be detected is if the AML system can spot a suspicious transaction.
 
Banks should protect themselves with technology using powerful data matching techniques that can search and flag transactions that break the normal pattern of activity for account holders. Coupled with software that can read data and detect anomalies, they can build an accurate profile of the customer, making it easier for money laundering monitoring systems to spot activity that banks should be reporting.
 
The action taken by the FSA against Coutts reflects the above position, and shows that AML frameworks need to operate over the entire lifespan of an individual, undergo constant monitoring and improvement and receive full,
wholehearted sponsorship from the company’s directors.
 

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