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DEVELOPING AN EFFECTIVE AML REGIME – KEY CHALLENGES AND RESPONSES

DEVELOPING AN EFFECTIVE AML REGIME – KEY CHALLENGES AND RESPONSES. Mike Trigg Group Head Financial Crime Risk. Standard Chartered Bank A Challenging Risk Matrix. Over 50 countries Diverse emerging markets Wide range of financial services. Keeping Pace with a Changing Regulatory Environment.

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DEVELOPING AN EFFECTIVE AML REGIME – KEY CHALLENGES AND RESPONSES

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  1. DEVELOPING AN EFFECTIVE AML REGIME – KEY CHALLENGES AND RESPONSES Mike Trigg Group Head Financial Crime Risk

  2. Standard Chartered BankAChallenging Risk Matrix • Over 50 countries • Diverse emerging markets • Wide range of financial services

  3. Keeping Pace with a Changing Regulatory Environment • Spread of legislation and regulation • Changing regulatory expectations • More proactive enforcement • More players (FAFT / IMF / Wolfsberg)

  4. Local versus Global • Variations between local requirements • Parent v local regulator • Local competition • Extra-territorial issues (Correspondent Banking, Offshore Booking,Sanctions)

  5. Response – 6 Point Programme • Stakeholder Engagement • Roles and Responsibilities • KYC • Suspicious Activity Reporting • Training • Monitoring

  6. Stakeholder Engagement • Parent Regulator • Local Regulators • Inter-Government Agencies • Industry Groups

  7. Roles and Responsibilities • Country Managers • Business line • MLRO structure

  8. Know Your Customer • Risk based approach • Mandatory Group standards • Approved local gap analysis • New accounts • Existing accounts (risk based)

  9. Suspicious Activity Reporting • Internal Reporting (automation?) • External Disclosures • Local challenges

  10. Training • Computer based (key messages, measurable, cost effective) • Specialised management programmes • Specialised product programmes

  11. Monitoring • Ongoing risk assessment • In-line quality assurance • Compliance risk monitoring • MLROs • Audit

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