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Caribbean Indigenous Banks Anti-Money Laundering Survey. An analysis of the local challenges. Patricia Hamilton CEO Caribbean Association of Indigenous Banks Inc. -. Know your customer (KYC) . Account Opening. -. Anti. money laundering standards and procedures. An Integrated Approach.
Know your customer (KYC)
money laundering standards and proceduresAn Integrated Approach
International, Regulatory, Industry, Third Party, Internal
Anti-Money Laundering Strategy
Business and organisation
Processes & Initiatives
Security & technology usage
Training and Awareness Program
Administrative and end
policies and procedures
Tactical short term
Cost of Compliance
AML is a key value; a function of the integrity of the company and as such must be promoted by directors and management.
Key values are supported by management behavior:
- Visible attention and appreciation
- Agenda item in board meetings
- Element of staff assessments
- Available budgets for IT, training etc.
- Status & powers of the AML officer
Most consider management to be supportive.
Where most Caribbean banks are
The above maturity model depicts how Compliance systems can evolve
Just above half report adequate manual & technological support.
77% have either invested or have plans to invest in the future.
A= Client Profiling
B= Transaction Profiling
C= Historic Client Behaviour
D= Pattern Recognition of Transactions
E= Peer Grouping
F= All of the Above
Most respondents report that their transaction monitoring system has all 5 features.
Most staff are considered to be familiar with consequences for breaches.
Experience in other jurisdictions shows that a common problem is a lack of skilled and experienced staff with anti-money laundering expertise.
How do we rank?
Most banks employ 1-5 staff whose primary duty is AML. The majority of these are responsible for Transaction Monitoring.
Although in small numbers, staff are considered to be adequately skilled in AML & CFT.
Account / Transaction
Policy & Procedures
Organization & Controls
Record Keeping / Retention
Training / Testing
33% have spent over US $100,000 on Transaction Monitoring.
A= Increase in staff
B= Enhancements to existing transaction monitoring system
C= Implementation of automated transaction monitoring system
Most respondents reported a combination of methods B, D & E.
A= Reliance on employees’ vigilance
B= Review of exception reports
C= Internally developed transaction systems/exception reports
D= Vendor supported automated transaction monitoring system
Most respondents (28%) reported a combination of methods A, B & C while 17% reported using all four methods.
However, 50% of these apply only to the Compliance department.
2. Effective governance structure to oversight line of business functions
3. Comprehensive and actionable policies and procedures to reflect global and country specific requirements
4. Appropriate compliance communication, awareness, reporting, and education plan
5. Process to identify and implement regulatory requirements timely and effectively