Anti-money laundering legal framework is increasingly turning into principles based, in place of prescriptive. Principles based totally rules provides large obligations that have to be met, however leaves the methods of assembly the ones duties as much as the man or woman. This is referred to as the Risk Based Approach.
This method is based on the belief that businesses are first-rate placed to know their clients, merchandise, operating shape and business surroundings. As a end result, organizations also are first-class placed to evaluate the risks of their business being used for money laundering or terrorism financing purposes. One such area requiring a danger based method is Ongoing Customer Due Diligence.
Ongoing Customer Due Diligence (OCDD) is a key element of your business’ manipulate framework in identifying, mitigating and managing money laundering and terrorism financing dangers. OCDD responsibilities apply with regards to all clients who’re required to be identified and established. OCDD includes transaction tracking. For medium to massive length businesses, automatic transaction monitoring is the fine solution for this regulatory requirement. Without computerized tracking, the assignment turns into massive and unreliable.
OCDD obligations additionally consist of keeping customer records up to date. The motive of reviewing your customer’s information is to think again their threat rating. During the evaluation procedure you may want to know whether your client’s enterprise has modified in either activity and / or expansion? Has your client been subjected to destructive media? Is your client now a Politically Exposed Person? Is your consumer now domiciled in a unique jurisdiction or has their commercial enterprise operations long past offshore?
Customers categorized as High Risk have to have their patron records reviewed as a minimum yearly. Business databases have to have the ability to provide reviews of High threat clients, including offshore customers and Politically Exposed Persons (PEPs). Not handiest will this information help the continuing management of AML / CTF programmes however it is also the type of key data your regulatory supervisor will count on you to provide and have easily available.
Kerry has labored with the economic market regulators in New Zealand, Australia and the UK.
Kerry became an Assistant Vice President and Deputy Money Laundering Reporting Officer for the Bank of New York in London. After leaving the Bank of New York she joined the Commonwealth Bank of Australia as the Anti-Money Laundering Compliance Manager in the Wholesale Division.
click here now operates an anti-cash laundering consultancy practice in Australia and New Zealand.
She holds a Diploma in Financial Markets, an International Diploma in Anti-Money Laundering, is a Certified AML Specialist and has a Fellowship with the Society of Anti-Money Laundering Professionals.
She has over 15 years analytical revel in and turned into previously a Financial Crime Expert for the Insurance Division of the Financial Services Authority within the UK.
She has investigated pass border money laundering and is skilled in imparting evidence in Local Court and High Court jury trials.
Formerly an Associate Regulator, Kerry worked closely with medium to huge length agencies (each listed and unlisted), assessing their exposure to operational risk, regulatory chance and financial crime danger. Where there had been weaknesses she prepared mitigation plans. These plans outlined the steps the agencies had to observe so as to bridge the diagnosed gaps. During this method she liaised closely with CEOs, Directors and Senior Managers.