MANAGING ANTI-MONEY LAUNDERING AND COUNTER-TERRORISM FINANCING REQUIREMENTS

R&C: To what extent are crimes related to money laundering and terrorism financing growing in frequency and complexity? How would you summarise recent trends in this area?

Taccogna: The greatest threat continues to come from international organised criminal networks, which are well funded, highly organised and motivated. The underlying criminal activity is the same – trafficking of drugs, weapons, humans and high-value commodities, including environmental crimes, tax evasion, fraud, corruption and terrorism. But the mechanisms for laundering the proceeds of this criminal activity change over time. In terms of trends, we would identify two. First, we are seeing an increasing use of technology and alternative banking platforms to move and obfuscate the origins of illicit funds. Second, fraud is one of the central activities of international organised crime. Regulators, including the Financial Conduct Authority (FCA), are increasingly concerned about the operational resilience of financial institutions’ payment systems, because of the well-publicised fraud losses that have come to light recently and because of the threat this activity represents to the financial system.

R&C: Could you outline some of the key legal and regulatory developments covering anti-money laundering (AML) and counter-terrorism financing (CTF) in recent times? Do companies need to accept that they now operate under heightened scrutiny, and react accordingly?

Apr-Jun 2020 Issue

FTI Consulting