The importance of an efficient AML/CFT (Risk) Model
28 August 2020
Since January 2020 EBA is the sole AML/CFT guardian
EU legislators and regulators are storming ahead with the fight against ML and TF via several actions on EU level. EBA now acts as the end-to-end AML/CFT guardian and enhances the Risk Factor Guidelines. Most national legislations make EU guidelines legally binding like BaFin via Guidelines and Q&As issued by the ESA or FMA via Circular FMA 3/2019. Hence implementation becomes a must have. We expect the Guidelines to become effective in January 2021.
What are the Risk Factor Guidelines about?
The Guidelines define how financial institutions have to identify and assess their ML and TF risks at a client individual and business-wide level. Assessment results determine the risk mitigating measures obliged parties have to implement.
How will you handle these revised Guidelines?
Implement in time and thoroughly. Avoid findings during audits as well as sanctions from supervisory authorities. Missing implementation of the Guidelines will very likely result in an incomplete ML/TF risk assessment. Data centricity is key to success for efficient processes and optimised Compliance Costs. Hence, leverage digitalisation and new data techniques.
BDO and Projective
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