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Challenges for the MLRO 23rd February 2009. Anti-Money Laundering and Counter Terrorist Financing Country Risk Assessment Process Jason Haines Head of Financial Crime Prevention, Huntswood Kit Dawnay Head of AML/CFT at Aegis. 1. Financial Crime Prevention - Challenges for the MLRO.
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23rd February 2009
Anti-Money Laundering and Counter Terrorist Financing
Country Risk Assessment Process
Head of Financial Crime Prevention, Huntswood
Head of AML/CFT at Aegis
The passive vulnerability of the system
and the active threat of money laundering
The process of assessment relies on information collection and mathematical modelling.
Anti-Money Laundering and Counter Terrorist Financing: Country Risk Assessment Process
Three are vulnerabilities:
Quality of regulation
Transparency of institutions
Quality of supervision and enforcement
Three are threats:
The prevalence of organised crime
Propensity to money laundering/terrorist financing
government officials and diplomats
financial services experts, journalists and professionals
security and law enforcement officers
FATF mutual evaluation reports
the World Bank and IMF
official government reporting
Closed access documents
Some social effects
MV Benjamin seizure in Ghana
Complete loss of Guinea Bissau to cocaine
Is the money coming back through West Africa?
Some countries provide stable investment environment
Lax AML/CFT standards
Real estate especially vulnerable
Corrosive impact on state integrity
Weakness of state structures
Drugs in West Africa
Ghana: address system lacking, at same time as emergence of offshore financial system.
Nigeria: corruption at all levels but varies: police, attorney general have reputation for serious corruption. Impact on neighbouring jurisdictions.
Senegal: money laundering carried out by family members or associates of president, combined with the politicisation of AML/CFT process.
Cote d’Ivoire: presidential family linked to CFA counterfeiting ring, linked to terrorist financing; sanctions enforcement against Charles Ble Goude, leader of the Young Patriots, is laughable – banks complicit.
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