Governance
What controls do we have? Who decides what?
Many stumble here
All the information, all the processes and all the systems...
No doubt, there are complex structures that must be aligned. Together, they must form a net that can prevent financial crime. Basis for reporting suspicious activities "SAR". Operational management requires clear responsibilities and roles in the organization. A committed leadership is necessary but not sufficient. The implementation from policies all the way to concrete instructions must be watertight to ensure compliance. Management needs reports and decision-making support. What decisions can be made? Where are the mandates? These questions need clear answers.
Yet another burden
Many businesses are proud of investments in new systems for AML. But they are "just" support for business processes that can be automated.
What remains is a continuous need to adapt and tune, to avoid false alerts, manage new risks, customer behaviors and rules.
Many of these decisions face internal competition for resources and time.
The "three lines of defence" provide overall support for the design of the governance. A successful implementation requires clear roles, decision-making and responsibilities.
What we have learned
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The line organization must be the executor of most of the steps in the AML Processes.
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But the "first line" may need to consolidate know-how and mandate to handle complex and deviant cases, outside of a main flow with a high degree of automation.
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Key figures for management should reflect both qualitative measures of compliance and quantitative measures of productivity.
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One size does not fit all. But made to measure may fit as well as tailored.