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AML Programs Operating in a Global Environment

AML Programs Operating in a Global Environment. Patty O’Connor Pan Asia Head, Compliance Surveillance Strategy Group Goldman Sachs. Tailoring Global Programs. Global KYC Programs Global requirements vs. local requirements Country-by-country analysis

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AML Programs Operating in a Global Environment

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  1. AML Programs Operating in a Global Environment Patty O’Connor Pan Asia Head, Compliance Surveillance Strategy Group Goldman Sachs

  2. Tailoring Global Programs Global KYC Programs • Global requirements vs. local requirements • Country-by-country analysis • Effectively managing the cultural differences • Lack of transparency Sanction Screening Programs • Local Jurisdictional Requirements must be met • OFAC/UK Sanction Programs – touch every aspect of FIs business

  3. Enforcement Trends and Implications Increased criminal enforcement • Insider dealing/Market Manipulation • Focus on international or offshore clients • Recent U.S. insider trading case - kept profits small to stay under radar • FCPA and Asia Anti-Corruption efforts • China - focus on “bribe givers” Implications for Firms • Surveillance design and constant refinement • i.e., identify patterns, capture smaller trading profits • Connecting the dots • Global clients mean global cooperation • Investigation and filing obligations in multiple jurisdictions • Filing obligations in Asian jurisdictions can vary greatly • Training employees – Suspicious Activity Awareness and Anti-Bribery • Effective Anti-Bribery Programs

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