“We Are The AML World”

One thing remains clear to me, in 30-plus years of addressing, debating, and trying to improve the global AML infrastructure: Serious engagement demands true collaboration.

Legendary composer and arranger Quincy Jones made something clear, when working on the song “We Are The World” in 1985. He had a dream team of performers. His request to all: “Please, check your egos at the door.”

The same applies to the AML community—law enforcement, regulators, and the private sector.

There is no one group that can improve what challenges us all in 2017. We need a sincere commitment to the ultimate goal of AML—protecting global society from those that would use the financial system to harm us.

[An aside: I was challenged recently on my three-legged stool. My challenger said it was really a four-legged stool, by adding those involved in technology. I respectfully disagree, since tech is enmeshed with all in the private and public sectors and not separate by any means.]

Get off the sidelines!

Nothing annoys me more that those who chirp and complain but never engage or work to solve problems. Improvement only comes from comments and stakeholder dialogue.

I coached and refereed youth sports for many years. I found that the number of “adults” who seemed to know it all was astounding.

Similarly, when we discuss compliance and other legal responsibilities, those who condemn the infrastructure but offer nothing of substance to improve the process provide nothing of value. This is why it is so important to provide input whenever the situation presents itself. Case in point—information sharing.

As I hope most of you know, the June plenary of the Financial Action Task Force (FATF) recently concluded with a new President (Santiago Otamendi of Argentina) and of course updated objectives.

I would urge you to review the objectives and summarize them for your management and staff. The objectives reflect the new FATF President’s priorities as well as input from the members.

I was particularly impressed with the notable push to continue engagement with the private sector; a call for partnership with the fintech and regtech sectors; and the need for FATF to enhance its public positions via social and traditional media.

At the same time, FATF has called for public comments on private sector information sharing with a draft guidance document.

While comments are due by July 31—I apologize for mentioning this so late in the process—there is ample opportunity to ask your organizations or trade groups whether they have filed comments.

And if not—why not?

There are many tenets regarding essential information in the AML field but FATF says simply:

“Information-sharing is critical for combatting money laundering, terrorist financing and financing of proliferation. Multinational money laundering schemes do not respect national boundaries.”

All of us agree with that sentiment but how we navigate privacy and jurisdictional hurdles are a major challenge. This draft guidance is well crafted but could use your operational, strategic, and legal input.

There is a section that has yet to be added in this document that cries out for help—“information-sharing between financial institutions which are not part of the same group.”

Get off the sidelines!

 Mid-Year Collaboration Updates

There are a few other projects underway that should assist our community.

• First, the ongoing projects with financial institutions and nongovernmental organizations on how to improve the hurdles to financial access. This has the strong support of the World Bank and the financial community. It is moving, but slowly. Congress is gathering more information on the use of remittances to commit terrorist activity but they have included NGO voices in those hearings.

• Concerns over human trafficking are growing and with it have been major efforts to address from both the private and public sectors. A report on new typologies has been released recently.

In addition, a project is underway to develop more red flags and indicators to help financial institutions detect and report this horrific crime.

• Finally, as we approach the May 2018 implementation deadline for FinCEN’s CDD rule, the Federal Financial Institutions Examination Council is working on examination procedures and actively seeking input on that and other possible changes to the next version of the FFIEC AML/BSA Examination Manual.

So get in the game and help. We have more than enough spectators.

*Key line from the song, “Let us realize that a change can only come, When we stand together as one.” Record of the Year in 1985 and co-written by Michael Jackson and Lionel Ritchie.