Broken down to its most basic level, an audit is a method by which firms seek an external opinion on their policies, procedures, systems and controls. Rather than an exercise in detecting shortcomings and failures, the process of a compliance audit should be viewed as a means of testing an AML/CTF framework to identify opportunities to undertake enhancements as well as highlighting any issues. In essence, the intention is to provide assurance that the firm is operating in an compliant manner within its own specific regulatory framework.
Last month Standard Chartered bank agreed to pay a $1.1 billion for both Anti-Money Laundering and Sanctions violations. This blog is an overview of the bank’s failures in relation to both cross-border violations and what they mean for firms.
Last year saw an unwelcome re-emergence of the so-called ‘laundromat’ scandal; the term, which harks back to the dry-cleaning establishments into which Al Capone and the Chicago mob funnelled their ill-gotten gains, was popularly attributed to a large-scale criminal money laundering scheme (uncovered in 2014) in which $20.8bn was laundered out of Russia through 96 countries and, more recently, to the rapidly developing scandal involving Danske Bank and its Estonian subsidiaries.
Assurance, or the use of auditors to search for problems at firms, can be very useful to the regulated community in all manner of ways, especially during the authorisation process or in respect of the EU's Payment Services Directive.
‘Compliance’ is the watchword in financial services, perhaps more now than ever. With new rules and regulations being introduced across Europe, most notably 4MLD, MiFID II, PSD2 and GDPR, Heads of Compliance across multiple industry verticals are now under major pressure to ensure their processes and procedures are up to date, adequate and compliant.
If you’ve been following the news over the past week or so you’ll no doubt be aware of the latest dossier on leaked information – titled the Paradise Papers – from the International Consortium of International Journalists (ICIJ).