ACAMS Australasia 2022 recap
OPINION: The Association of Certified Anti-Money Laundering Specialists (ACAMS) held its 2nd annual AML & Anti-Financial Crime Conference for Australasia in Sydney 21st and 22nd June 2022. Anthony Quinn, Founder of Arctic Intelligence attended the event and connected with many peers, regulators, industry leaders and risk and compliance professionals for the first time since the pandemic. Here is a snapshot of the two-day event.
There were so many takeaways and snippets to digest but here are some key highlights:
- Hearing from Nicole Rose from AUSTRAC about the massive amount of activity that they have done over the last few years and their program of work over the coming years (with a focus on boards/governance, tone from the top, accountability and capability uplift across the gaming, hotels, pubs and clubs sectors). That was a seriously impressive rundown!
- Financial Action Task Force (FATF) are coming back to do the follow-up to Australia’s last 2015 Mutual Evaluation Report in 2024-2025. Is a 9 or 10 year gap far too long? Highly plausible – This may certainly have contributed to the apathy in driving Tranche 2. Also seems that Australia unlikely to ever be grey-listed in spite of the slow adoption for Tranche 2.
- Other key themes were increasing demand and limited supply for AML skills/experience which is exponentially increasing and going to get worse, organisations see #regtech as a way of partially solving the gap and renewed calls for collaboration with tech, regulators, reporting entities to explore next gen financial crime utilities (KYC/CDD, screening, transaction monitoring, reporting and if enterprise-wide financial crime risk assessments – we’re 100% all in!)
One of the best sessions from this weeks Association of Certified Anti-Money Laundering Specialists (ACAMS) conference for the Australasia Chapter was the session on lessons learned from recent enforcement actions by Marsic Sonja (who prosecuted CBA and Westpac) and Alex Edith from AUSTRAC, who highlighted in great detail what they look for businesses to demonstrate – the key take outs were:
- Coverage – that enterprise-wide risk assessment (EWRA) and the AML/CTF program is tailored to the business, reflects the risk environment, covers all designated services and ensures controls are aligned to the program and in line with risk appetite and is embedded as a living exercise capable of repetition by being embedded into risk management framework
- Board and Senior Management oversight – clear definition of risk appetite statement clearly communicated across the organisation and reflective in EWRA with a feedback loop to manage risks outside risk appetite/tolerance through detective and preventative controls. Based on a sound methodology, with a clear audit trail of risk and control assessment and methodology/logic used – not a set and forget exercise but a perpetual process and must be well maintained and current. Critical for the ML/TF risk assessment to be based on a sound and clearly documented methodology with explainable logic of how inherent risk, control effectiveness and residual risks are assessed. Clearly defined roles, responsibilities, accountabilities and reporting lines – with a mandate and appropriate resources to execute. Examine the information flows on AML to the Board and evidence of appropriate feedback loops to improve, escalation procedures and assurance and oversight procedures embedded into the cultural fabric of the business
- Information management and resources – AML program is NOT a statement of intent and they seek clear evidence of appropriate and skilled resourcing and supporting systems. If poor processes, procedures, systems that don’t aggregate data with good record keeping then very hard to demonstrate how this works.
In a nutshell, ML/TF risk management and governance frameworks are more often than not the MAIN reason of failure and all the other failings in KYC/CDD, Transaction Monitoring and other obligations are just a SYMPTOM of not getting the basics right.
This is why Arctic Intelligence exists – we have developed a suite of enterprise-wide financial crime risk assessment platforms that are fully configurable and flexible to get the basics right so please get in touch if you would like to learn more.
In the meantime here is a link to the presentation materials.
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