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ReadersSpeak





        AML enforcement fines at all-time high                                     regulatory standards.
                     W            e wish to thank Martin Cheek, vice president of   Kroll, the most common failings cit-
                                                                                   Over the past five years, according to

                                                                                   ed when issuing fines involve AML
                                  SmartSearch,  a  provider  of  an  anti-money  laun-
                                                                                                             activity
                                                                                                 suspicious
                                                                                   management,
                                  dering verification service, for this commentary:
                                                                                   due diligence. Each of these is central
        In 2016, $889 million worth of fines were levied globally to institutions that   monitoring  and  customer  standard
        failed to adhere to anti-money laundering and sanctions laws. The same year   to successful AML strategy—without
        also saw nearly $7.5 billion in fines issued for bribery—and it's a safe bet that   them, institutions are vulnerable to
        wherever bribery exists, there is also money laundering to ensure that funds   money launderers.
        remain hidden from authorities.
                                                                                   In addition to large financial insti-
        In 2020, the numbers were vastly different: $2.22 billion in fines for money   tutions,  small  businesses  can  be  a
        laundering, compared to $2.42 billion for bribery. The first six months of 2021   popular choice to launder money be-
        saw $994 million in fines assessed over 17 actions. Large AML actions in 2021   cause many of them lack resources to
        included $390 million against Capital One for violations of the Bank Secrecy   conduct thorough background and
        Act and $100 million against cryptocurrency platform BitMEX in a settlement   sanctions checks—and because, as
        with two U.S. regulators.                                                  small fish in a large pond, they're not
                                                                                   usually the focus of  investigations.
        Authorities around the world are cracking down on money laundering—a       This increases pressure on business-
        good thing. But if you break down the numbers further, the picture isn't as   es large and small to have AML and
        rosy: the number of fines issued for money laundering was the same in 2019   sanctions protocols in place to protect
        and 2020, yet only $444 million worth of fines were issued in 2019. As Kroll,   themselves should someone try to
        the company that compiled these figures, noted, the total value of fines rose   take advantage of this lack of over-
        because of "numerous substantial fines by Nordic regulators." Thus, it's not   sight.
        necessarily that governments are more aggressive about investigating money
        laundering—they're instituting harsher punishments for failing to meet     Thankfully, AML compliance is now
                                                                                   easier than ever. Artificial intelli-
                                                                                   gence reduces check times to seconds
                                                                                   and frees staff from referencing each
                                                                                   new customer against hundreds of
                                                                                   sanctions lists. Additionally, more
                                                                                   sophisticated platforms provide sus-
                                                                                   picious activity monitoring, so if a
                                                                                   client lands on a sanctions list, busi-
                                                                                   nesses won't be caught unawares.

                                                                                   Money laundering is a perennial
                                                                                   concern worldwide. Not only do the
                                                                                   assets involved usually stem from il-
                                                                                   legal activity, they can often be fun-
                                                                                   neled back into criminal enterprises,
                                                                                   making it difficult for law enforce-
                                                                                   ment to police them. Yet, despite the
                                                                                   obvious threat money laundering
                                                                                   poses to stability and the rule of law,
                                                                                   many see AML regulations as red
                                                                                   tape making it more difficult for busi-
                                                                                   nesses to operate effectively. The op-
                                                                                   posite is true. Using appropriate AML
                                                                                   technology, businesses can go about
                                                                                   their work, secure in the knowledge
                                                                                   they are protected.

                                                                                   Do you have knowledge to share?
                                                                                   Please send your commentary or ques-
                                                                                   tions to greensheet@greensheet.com.



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