INDEPTH FEATURE
Anti-Money Laundering 2024
January 2024 | FRAUD & CORRUPTION
financierworldwide.com
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While the international community has made significant progress in strengthening safeguards against money laundering and terrorist financing, there is still a long way to go. Companies need to regularly review and update their anti-money laundering policies and procedures, and regularly assess the risks they face. Technology can help. Know your customer and transaction monitoring, for example, can be made quicker and less prone to human error.
UNITED STATES
J.S. Held
“One would likely never imagine compliance as being a sought-after role, but like everything else, times are changing. However, the culture of compliance is not simply changing because it is the latest fad to hit the job market; rather, it is due to some extreme situations that continue to take their toll on the world. While Russia and Ukraine seem like a world away from the US, we see the effects that this conflict is having on the everyday lives of those working in compliance departments. As such, we are seeing a concentrated effort by compliance teams to ensure that any potential touch points within Crimea are vetted and then vetted some more.”
CANADA
EY Canada
“Canada has witnessed a rise in financial crimes, fuelled by an economic downturn and advances in technology. Fraudulent exploitation of new payment methods, increasing use of cryptocurrency in scams, intermediaries creating shell companies to hide transactions, and the operation of unregistered money services businesses (MSBs) to evade regulations are prevalent trends. Meanwhile, as evidenced by ongoing public-private partnerships, the real estate, gaming and crowdfunding sectors, human trafficking, the illegal wildlife trade, and unauthorised cannabis activities remain key focuses for the Canadian government.”
UNITED KINGDOM
WilmerHale
“Fraud and financial crime now make up approximately 40 percent of all reported crimes in the UK. You do not even need to step outside of your home to be the victim of financial crime, as sophisticated scammers can target the victims of crime over the telephone and internet. Therefore, the government and UK regulators are placing statutory and regulatory duties on corporates to counter fraud, which in turn shapes how they assess and respond to financial crime. Beyond any change in the government in 2024, we will see further initiatives to encourage corporates to tackle financial crime.”
REPUBLIC OF IRELAND
Kroll Advisory (Ireland) Limited
“Combatting financial crime continues to evolve significantly in Ireland. This evolution can be attributed to heightened regulatory scrutiny and expectations but perhaps more so to the growth in the perpetrators’ use of new and increasingly sophisticated technologies. In addition, the continuing growth of high-risk sectors in Ireland lends itself to greater focus from local and international regulators. Digitalisation of know your customer (KYC) documentation is increasing in popularity. Artificial intelligence (AI) and machine reading of all data and documentation is key and companies are focusing on how best to exploit AI while continuing to maintain a risk-based approach.”
GERMANY
Alvarez and Marsal
“Cash transactions and real estate acquisitions, or even the combination of both, remain areas where most money laundering takes place. However, since April 2023 it is no longer possible to purchase real estate with cash in Germany. In its 2022 annual, the German Financial Intelligence Unit, which is part of Germany’s customs authority, also mentions trade based money laundering and organised crime as among the biggest risk areas. Further, methodologies to circumvent financial sanctions against Russia have increasingly become the focus of attention in Germany’s financial crime landscape.”
SWITZERLAND
KPMG Switzerland AG
“In November 2023, the Swiss Financial Market Supervisory Authority (FINMA) released its annual risk monitor, reaffirming the persistent challenge of money laundering risks within the renowned Swiss financial centre, known for its global cross-border wealth management. The Swiss wealth management sector is witnessing an increase in new clients from emerging markets, exposing itself to a notable corruption threat.”
SINGAPORE
Premier Law LLC
“Recent trends in financial crime in Singapore highlight the increasing sophistication of illicit activities, with cyber crime and technology-driven fraud gaining prominence. From January to June 2023, 75 percent of all reported crimes were white-collar crimes, online scams and other cyber crimes. Among these, money laundering remains a significant concern, fuelled by Singapore’s status as a global financial hub. Singapore has implemented robust regulations and compliance measures to counter money laundering.”
JAPAN
PwC Japan Group
“Recent developments in the financial crime landscape have revealed a considerable escalation in specialised fraud, unauthorised transactions linked to internet banking, and a rise in cyber attacks executed through ransomware. These trends underscore the growing sophistication and reach of financial criminals. Additionally, there is an increasing trend of products being indirectly sold in sanctioned countries via intermediary third-party nations, amplifying the complexity and risk of non-compliance with international trade sanctions.”
AUSTRALIA
FTI Consulting
“Financial crime issues have received a relatively higher profile in Australia over the past few years. There have been a number of high-profile cases of companies allegedly failing to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) legislative obligations which have resulted in significant financial penalties being imposed by regulators, and in some cases royal commissions and commissions of inquiry. These cases have generated significant media attention and have involved the banking, gambling and money transfer businesses.”
SOUTH AFRICA
KPMG Services (Pty) Ltd
“Recent trends in financial crime in South Africa reveal a complex and challenging landscape, particularly regarding money laundering and other financial crimes. South Africa continues to grapple with high levels of financial crime and faces significant threats from sophisticated criminal networks. Being the major financial and economic hub in the southern African region, with a largely cash-based market and relatively sophisticated banking sector, South Africa is an attractive target for both domestic and international criminal syndicates.”
CONTRIBUTORS
Alvarez and Marsal
EY Canada
FTI Consulting
J.S. Held
KPMG Services (Pty) Ltd
KPMG Switzerland AG
Kroll Advisory (Ireland) Limited
Premier Law LLC
PwC Japan Group
WilmerHale