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Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.

Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc. Hot Topics in AML. Integrating KYC Information and Transaction Monitoring Growing expectations for Comprehensive Client Reviews across businesses and geographies

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Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.

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  1. Pamela J. JohnsonManaging Director, Global Head, AML & Sanctions ComplianceCitigroup Inc.

  2. Hot Topics in AML • Integrating KYC Information and Transaction Monitoring • Growing expectations for Comprehensive Client Reviews across businesses and geographies • Increased expectations regarding depth and breadth of periodic reviews • KYC and the 4 F’s FATF, FinCEN, FFIEC, FATCA

  3. Integrating KYC Information and Transaction Monitoring • Client risk score/ratings and profile information driving monitoring treatment • Monitoring activity driving KYC profile updates • Monitoring history influencing client risk score/ratings • KYC profile details, anticipated activity, expected volumes, etc, leveraged in alert investigation

  4. Growing Expectations for a Comprehensive Client View • Growing expectations for KYC programs to profile clients across businesses and geographies • Challenge of identifying and linking all client entities and accounts in a common profile • Data protection and privacy requirements may limit the flow of information for these purposes • Increasingly complex requirements for client relationships with multiple related parties and accounts. • In these circumstances, determining who owns the relationship, what KYC requirements apply, and how they will be satisfied on an ongoing basis

  5. Ongoing Due Diligence / Periodic Reviews • Expectations regarding depth and breadth of periodic reviews • Update of KYC profile information and data • Actual vs. anticipated activity • Detailed transaction reviews • Investigations and alert activity • Trigger events vs. periodic scheduled reviews • Targeted high risk client reviews • Orchestrating cross-border and/or cross-business periodic reviews

  6. KYC Programs and FATCA • Navigating through complex international requirements (FATF vs. regulatory expectations in key markets vs. FATCA) • FATCA, FATF, FinCEN and FFIEC effect on beneficial ownership requirements globally • Classification of existing clients under FATCA and documentation remediation • Potential practical issues and consequences

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