Financial Institutions Must Take Proactive Approach to Anti-Money Laundering and Combating Financing of Terrorism
A recent report by the Financial Action Task Force (FATF) emphasizes the importance of financial institutions taking a proactive approach to anti-money laundering (AML) and combating financing of terrorism (CFT). The report identifies high-risk countries and geographic areas that pose a significant threat to global stability and security.
Risk Assessment
The risk assessment process is a critical component of AML/CFT compliance. Financial institutions must conduct comprehensive assessments of ML/FT risks, taking into account the characteristics of their business environment and business strategy. The risk assessment should be conducted in a firm-wide and consistent manner with the involvement of the Board.
Expected Actions
Financial institutions are expected to:
- Establish an enterprise-wide policy and specific methods for conducting risk assessments
- Conduct comprehensive and specific evaluations of ML/FT risks, with the Board taking the lead in ensuring coordination and collaboration among all relevant departments
- Analyze the status of suspicious transaction reporting, including quantitative information such as:
- Number of reports by division
- Location
- Reporting factors
- Detection scenario
- Document the results of risk assessments and utilize them for developing measures necessary for risk mitigation
Risk Mitigation
Risk mitigation is a critical component of AML/CFT compliance. Financial institutions must implement effective measures to mitigate identified risks based on their level of risk exposure.
Customer Due Diligence (CDD)
CDD is a critical element of risk mitigation. It involves:
- Identifying and assessing ML/FT risks with regard to a specific customer
- Reviewing information about the customer and their transactions in light of the results of risk assessment
- Determining measures necessary to mitigate identified risks
Financial institutions are expected to:
- Collect and verify fundamental information about customers and their activities and transactions
- Compare that information with the results of risk assessment and determine effective measures to mitigate identified risks
- Undertake enhanced mitigation measures in cases where ML/FT risks are high
Conclusion
The FATF report highlights the critical importance of financial institutions taking a proactive approach to AML/CFT compliance. By conducting comprehensive risk assessments, implementing effective risk mitigation measures, and collecting and verifying fundamental information about customers, financial institutions can significantly reduce the risk of ML/FT activities and contribute to global stability and security.