17th FIBA AML Conference Takeaways

    • No regulatory gaps exist as LATAM countries have made good progress in this area, however still work to be done in terms of effective implementation;


    • Improvement is being made in the area of information exchange;


    • In terms of de-risking, while determining your foreign respondent’s financial crime risk management capability is of primary importance, cost and profitability are important factors;


    • Cyber issues are becoming intertwined with AML which calls for greater collaboration between the AML and cyber units of a financial institution;


    • While Know Your Customer’s Customer (KYCC) is not a required standard of due diligence it is reasonable in order to clear alerts;


    • Keep doing what you are doing and regulators will be looking for more public/private engagement. Regulators cannot do it without you.
    • TRANSPARENCY and TIMELINESS will make a big difference for foreign financial institutions in their relationships with correspondent banks.


    • Info sharing within internationally active banks and a clear assessment of risk is important.


    • BSA is not to be in a silo within an institution; it is holistic within any organization. Listen to BSA and take them seriously.


    • Make a good faith effort and document, document, document.


    • While innovation is “front and center” at larger banks, survival is the greatest focus for smaller banks. The risk of not having adequate capabilities presents a real threat to both large and small banks alike.


    • Technology is a great tool; however, it should not replace human judgement.