James ThomasEditor, inCOMPLIANCE, ICA
- United Kingdom
Community Zones participated in:Change and Culture Community Zone Communication Community Zone Fraud Community Zone Leadership Community Zone
We didn't have time to cover all of the audience questions submitted during Jonathan Bowdler's session today, including the following:How can I easily transfer my compliance skills from one regulatory sector to another?How do you manage navigating the "dead man's shoes' syndrome? Moving jobs is not always an option.RegTech providers suggest that the compliance officer of the future will need to understand coding. What do you think? Please feel free to join the conversation and share your thoughts on the above
A couple of questions from this morning's session that we didn't have time to cover:- How difficult is it to show the money movement from the predicate crime - eg trafficking wildlife to the clean money? Is organised crime always involved?- UBO registers unfortunately don't work. It is a good starting point though. Do you have any ideas how this can be improved?Please feel free to discuss the above
A couple of questions from the audience that we did not have time to cover during the panel session:- With sanctions risk how can we know our customers’ or suppliers’ customers?- We use a platform that checks clients/third parties on a daily basis for adverse news, sanctions etc. Do you think we should train staff to manually check also?We'd love to hear any answers you might have to these. Please join the conversation!
Some outstanding questions from this session:What is predictive analytics and how do you see this working/benefiting finance industry?Do you think with working from home it is harder for teams to come together and help reduce risks?Please feel free to share your thoughts on these, and any other questions you had emerging from the discussion
Outstanding questions from the audience for today's session on sanctions:Where do you see the future for divergence from the US and EU approach, eg with Iran?How are you training staff to manage SSI risks?What do you see as the main challenges regarding the operational effectiveness across the bank in preparation / response to new sanctions?Does the panel have some advice on proactive ways of educating oneself/staying informed about sanctions?What are the key challenges with managing the OFAC 50% rule?Can or should compliance professionals be held responsible if the client teams do not do the right thing when an individual is found on the OFAC list? (The above question is in relation to a Russian individual.)Please feel free to share your thoughts on these, and any other questions you had emerging from the discussion
We had many, many more questions than we could answer during today's session on the FinCEN leaks. Here is a selection:If we are only seizing less than 1% of all funds that are laundered, what is the point in the huge sums of money invested in fighting ML? How do we invoke change?Isn't it a cultural issue to let transactions go through that were flagged and reported as suspicious?Banks have been fined over and over again - is it time to start sending MLROs and senior compliance officers to prison?What's the point of apportioning blame - let's focus on fixing the access and PREVENTION of money laundering and providing continued access to these criminals?When you say that banks should close accounts if there is money laundering, surely they are just going to go elsewhere? Surely it requires criminal charges?What needs to change about the way we think as FinCrime professionals? Lots of talk on procedure, but do we need to talk about culture/values/attitude too?Is there any type of interbank information exchange about money laundering attempts?FATF evaluators gave FinCEN the top rating possible for a FIU in its 2016 mutual evaluation of the U.S.. Was it wrong? Are FATF's evaluation criteria wrong?How can banks measure success given they don't control the law enforcement element?What about the TMNL project - why aren't more nations starting something similar?Please feel free to share your thoughts on these, and any other questions you had emerging from the discussion
Some outstanding questions from today's panel session on technological advances in transaction monitoring:How can tier-2 banks create legal and information sharing agreements in order to actually deploy federation models? Are there any existing examples of this? How do you consider the suspicious transactions MISSED by your systems in continuous improvement?Does the AI discount alerts automatically based on loaded scenarios added to the system or does it refer all transactions for human checking and investigation?AI here is machine learning. If this is true, machine learning needs data, lots of data. If so, how realistic is it to expect AI to be applicable "now"?Someone I knew is a victim of a social media business scam and scammers had used mule account. Would AI help with mule accounts or create more false positives?Please feel free to share your thoughts on these, and any other questions you had emerging from the discussion
One question from the audience that we didn't have time to cover during Greg Slayton and Nick Frost's presentation: Is the risk-based approach about agility in responding to what is on the mind of business leaders vs ticking a box for regulators?We'd love to hear your thoughts on the above.