Financial Crime World

Effective AML/CTF/Sanctions Risk Management in the Middle East and North Africa Region

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The Middle East and North Africa (MENA) region is a high-risk area for Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Sanctions (AML/CTF/Sanctions). A robust risk management framework is essential to identify, monitor, and mitigate these risks.

Key Risk Indicators (KRIs): The Backbone of Effective Risk Management

The report highlights the importance of KRIs in identifying potential AML/CTF/Sanctions risks. KRIs should generate actionable intelligence to inform decisions, actions, and directions related to AML/CTF/Sanctions risk management.

Key Points

  • Risk Assessment: Regular risk assessments are necessary to identify potential AML/CTF/Sanctions risks.
  • Actionable Intelligence: KRIs must provide actionable intelligence to guide decision-making and action.
  • Critical Controls: Effective controls must be in place to address critical risks, and objective KRIs should be defined to ensure these controls are working as intended.
  • Continuous Improvement: Compliance officers must continually seek to improve their understanding of evolving risks and take proactive steps to manage and mitigate AML/CTF/Sanctions risk exposures.

Importance of Periodic Refreshment

The report emphasizes the need for periodic refreshment of risk assessments and KRIs to ensure they remain relevant in a dynamic environment. This is crucial to stay ahead of emerging threats and maintain effective risk management.

About the Authors

  • Michael Matossian: EVP and Chief Compliance Officer at Arab Bank plc, with over 30 years of experience in regulatory risk management, anti-money laundering, and compliance.
  • Sharon Craggs: Group Compliance Officer for the Arab Banking Corporation (ABC), Bahrain, with expertise in multiple product lines including financial markets, corporate banking, consumer banking, wealth management, and financial crime compliance.

MENA Financial Crime Compliance Group

The MENA Financial Crime Compliance Group (MENA FCCG) is a voluntary body that seeks to bring collective action in the fight against money laundering and terrorist finance in the region. The group comprises 12 banks representing eight MENA countries.