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10 The variables Requirements of the law Effective implementation by the covered financial institutions and DNFBPS Understanding of why AML/CFT laws are needed Consequences if country does not comply
11 The driving forces G20 decisions and communiques FATF standards and evaluations Global Forum on Exchange of Tax Information and their peer review reports European 4th and 5th Directives on AML
12 Consequences if country does not comply Public listing as noncooperative countries FATF the Global Forum European Commission/Parliament Negative commercial effect foreign transactions foreign direct investment access to correspondent banking facilities Possible reputational damage
13 Good and bad practices examples The role of CEO/Board: From policy statements and missions to promotion of culture within organization, internal communication, adequacy of resources and interconnection with HR, IT; Implementation and improvement within 3 lines of defense Ethical climate, led by example and collaboration
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18 The objectives Financial crime, money laundering and terrorist financing is a global issue that needs to be handled both locally and globally The need for establishing national mechanisms to ensure adequate cooperation and coordination at policy level between ministries and operational agencies In order to combat the issue you need to understand the real risk
19 The obstacles The risk of legislation not being up to date The length of the law makers process in amending or add legislations for the purpose Conflicting laws and regulations Technology and analytics Data and information Trust: - Private to private - Public to Public - Public to Private
20 Let s discuss: Have we lost sight of the purpose? Spirit of the law
21 Collect the clues and connect the dots:
22 Cooperation in reality how efficient is it? What does the FAFT say in the recent MER of: Ireland Denmark Sweden Belgium Norway
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24 What does the future behold? Future of Financial Intelligence Sharing programme Understanding the role of public-private financial information-sharing partnerships to detect, prevent and disrupt crime Report available at
25 FISPs What are financial informationsharing partnerships (FISPs)? And what is their role in the disruption of crime?
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28 Joint Money Laundering Intelligence Taskforce (JMLIT) A partnership between the UK National Crime Agency, law enforcement and the financial sector to cooperate on combatting money laundering Vision and purpose: to exchange and analyse intelligence in order to better detect criminal behaviour, understand how financial systems can be exploited and deter financial crime
29 Operational priorities Understanding and disrupting the funding flows linked to bribery and corruption Understanding and disrupting trade based money laundering Understanding and disrupting the funding flows linked to organised immigration crime, human trafficking and modern slavery Understanding and disrupting money laundering through capital markets and Understanding key terrorist financing methodologies
30 Results A better coordinated response to police investigations in relation to the recent London and Manchester terrorist attacks Development of money laundering typologies currently being used by criminals to launder criminal proceeds 63 arrests of individuals suspected of money laundering Instigation of more than 1000 bank led investigations into customers suspected of money laundering Identification of more than 2000 bank accounts previously unknown to law enforcement
31 Further Reflections for Policymakers: Political consensus Supervisory response Enforcement implications Allocation of resources Reporting efficiency and privacy
32 Conclusion/take aways: Establish a true sense of urgency between the law makers, public and private sector Create the arena for information sharing Establish the trust Remember the purpose
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