Sie sind auf Seite 1von 20

Global AML Survey

By KPMG
Input for preparation of Personal Action Plan

Kiev, Ukraine: AML/CFT & International Sanctions


Seminar

Kiev 24-27 May l 2016 Adriana Consultancy Consortium


KPMG Global AML Survey 2014

Challenge of far-reaching AML standards:


New regulations in Asia, FATCA, 4th EU AML Directive
AML compliance is no longer “just” compliance: it is a
complex and overarching function across legal, risk,
operations and tax issues.

At local and regional (national) level?

At global level ?

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Respondent Profile

Job Title Geographical Area

37% Head of AML Compliance 27% Western Europe

23% Head of Other Departments 26% Asia Pacific

16% Managers 18% Middle East and Africa

13% Officers 11% Russian and Eastern Europe

6% Directors 8% North America

5% Others 10% Others

100% 100%

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Key Headlines:

• What priority for senior management?


• Cost of compliance
• Global Approach
• PEPs
• KYC
• Sanctions compliance
• Transactions Monitoring
• Regulatory Approach

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Senior Management ?

AML moving up the agenda for senior


management with a very high percentage
of respondents that say that AML is indeed
a priority for senior management.

When conducting risk assessments AML is


considered a high risk area.

AML is highest risk in developing countries


92 % in Africa and Middle East

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Cost of Compliance ?

Costs rising at an average rate of 53 percent for


banking institutions

This exceeds previous predictions made in 2011


by 40 % !!!!

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Global Approach

YES, there is a global approach in global


banking groups BUT

Only 32 % of respondents with a global policy


are indeed able to maintain global consistency
across subsidiaries and branches

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


PEPs

PEPs remain area of focus

Senior management more engaged

This is important as senior management needs


to be involved in the sign-off process.

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


KYC

KYC is continued area of concern

Increased regulatory scrutiny of KYC


procedures

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Sanctions Compliance

A big Challenge:

75% now use MT20ZCOV SWIFT


But

Only 52% said that if required information


was missing, the MT20ZCOV would be
rejected

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Transaction Monitoring

TM systems are the greatest expense in


AML spending

However:

Satisfaction is low as regards the TM


efficiency and effectiveness

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Regulatory Approach

Ranked as TOP concern for AML


compliance

84% of respondents stating that the pace


and impact of regulatory changes is a
significant challenge to the FI.

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Cost of Compliance ?

Costs continue to increase

• Senior management needs accurate cost


forecasting
• Remains key area of weakness
• 78% of survey respondents report increases in total

AML activity investment


• next 3 years a further need to invest in compliance

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Budget investment
Click to edit Master text styles ‒ Third level
• Second level

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Other Challenges

 Foreign Account Tax Compliance Act (FATCA)


 USA’s Approach to Tax Evasion by its Nationals
 Requires Foreign Financial Institutions to Enter into an
Agreement with the IRS and Disclose Information
 Penalties for Non-Compliance
 KPMG Survey – 47% Stated that Compliance Departments
would be Sponsoring FATCA

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Recommendations for Boards

1. Nominate a member of the Board with special responsibility


for maintaining effective AML controls

2. Ensure a broad assurance program is in place which tests


systems, processes and procedures

3. Prepare effectively for regulator visits and ensure that the


Board has all necessary information to demonstrate
• Accuracy
• Oversight
• Control
Kiev 24-27 May 2016 -- Adriana Consultancy Consortium
Risk Management and Internal Controls

 Appoint a Chief Risk Officer (CRO)


 Ensure the Compliance Function
 Ensure the Internal Audit Function

 All
with Authority, Stature, Independence,
Resources and Access to the Board

 Internal Communication

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Role of Compliance Officers

 Ensure that the bank complies with existing legal


and regulatory requirements
 Report directly to management
 Ensure senior management engagement
 Instill compliance at all levels within the

organization
 Create an atmosphere of ethics and trust
 Recognize threats and vulnerabilities
 Train staff at all levels

Kiev 24-27 May 2016 -- Adriana Consultancy Consortium


Homework
Personal Action Plan

Or

Benefit Analysis Form

- What are your priorities ?


- where does your bank stand ?
- what will you take back to the office ?
Kiev 24-27 May 2016 -- Adriana Consultancy Consortium
THANK YOU
Click to edit Master text styles ‒ Third level
• Second level

Thank you

Adriana Holtslag-Alvarez
Consultant to the EBRD;
Project Leader Seminar

adrianaholtslag@gmail.com
Kiev 24-27 May 2016 -- Adriana Consultancy Consortium

Das könnte Ihnen auch gefallen