Anti-Money Laundering (AML)

Money laundering isn’t a novel practice. Organized criminals have used such techniques for a long time to hide the origin of the illegally acquired funds. Moreover, the advent of different financial solutions like neo-banks, e-wallets, and cryptocurrency has made combating money laundering challenging. 

The United Nations Office on Drugs and Crime (UNODC) estimates that criminals launder €715 billion to €1.87 trillion annually. This has urged regulators to introduce stringent Anti-Money Laundering (AML) regulations to mitigate financial crime risks such as money laundering.

Understanding Anti-Money Laundering 

AML includes the measures and guidelines established by governments and financial firms to prevent the illegal conversion of “dirty” funds into “clean” money to make them appear legitimate. Criminals use money laundering tactics to legitimize the proceeds of different illicit activities, such as terrorism, corruption, and drug trafficking.

What are the Stages of Money Laundering? 

Three stages of money laundering include:

1. Placement: This stage involves placing illegally acquired money in a legitimate financial firm. Criminals use different tactics and channels to hide the origin of their funds. These may include:

• Legitimate cash businesses such as car parks, car washes, tanning salons, and casinos
• Trusts and offshore firms
• International bank accounts2. Layering: During this stage, criminals mix dirty and clean money, making it difficult to trace the true origin of the illicit proceeds. Layering is complex, as money launderers use sophisticated bookkeeping tricks to hide the audit trail. This may involve:

• Transferring money between several banks or different accounts within the same financial firm
• Moving funds across international borders
• Investing in real estate
• Converting cash into wire transfers, stocks, and money orders3. Integration: In the final stage, money launderers return the funds to themselves without arousing suspicion from tax or law enforcement authorities. They do this with: 

• Fake employees
• Extending loans that are never repaid
• Investing into a property, jewelry, artwork, high-end cars, and other high-priced commodities

When to Perform AML Screening?

Financial institutions are required to conduct anti-money laundering screening of entities they are doing business with in several circumstances, which are as under:

• Firms have to perform AML checks during the account opening process
• The level of risk that an entity may pose changes over time. Businesses must regularly check their risk level by conducting efficient AML screening.
• Companies should perform AML checks during the employment processes
• Organizations are required to conduct AML checks to identify the Ultimate Beneficial Owners (UBOs) of any company they are doing or going to do business with

Key Components of AML Screening

1. Customer Due Diligence (CDD): Just like Know Your Customer (KYC), CDD involves validating the identity of entities and assessing their potential risk levels. This involves understanding the nature of business, the purpose of transactions, and the origin of funds.
2. Transaction Monitoring: Financial firms must have robust monitoring solutions in place to identify and report unusual transactions. The transaction monitoring solution analyzes amounts, patterns, and frequency of transactions to detect suspicious activities.
3. Risk Assessment: Different entities carry different risk levels. Thus, banks and financial firms should conduct a risk assessment to categorize the risks and better allocate resources.
4. Screening against Sanctions Lists: The AML process also involves screening entities against the global sanctions list to prevent dealing with organizations linked to illicit activities.
5. Training the Staff: Well-informed staff serves as the first line of defense against fraud such as money laundering. Proper training and awareness programs are crucial to equip staff to identify and report unusual activities.

Best Practices for Effective AML Screening

1. Robust AML Policy: Develop a comprehensive anti-money laundering policy customized to your business’s operations and the legal requirements of your country. The AML policy should outline staff roles, responsibilities, processes, and escalation procedures.
2. Automated Tools: Leverage AI technology to improve AML efforts. AI-powered AML compliance solutions efficiently process piles of data, identify patterns and anomalies, and ensure greater accuracy.
3. Real-Time Screening: Deploy real-time transaction screening solutions to detect and flag unusual activities quickly. This proactive approach helps reduce financial crime risks, such as money laundering, going unnoticed.
4. Collaboration with Regulatory Bodies: Establish open communication channels with the regulatory authorities. Reporting suspicious transactions timely and collaborating with authorities show your business’s commitment to maintaining compliance.
5. Third-Party Due Diligence: Conduct comprehensive due diligence on their AML processes when dealing with partner entities. Ensuring that the business associates adhere to the same standards helps prevent involvement in illicit activities like money laundering.
6. Data Security and Privacy: Safeguard clients’ confidential details and financial data with advanced cybersecurity measures. Complying with data protection laws enhances AML efforts and clients’ trust.
7. Regular Audits and Testing: Regularly review and analyze your AML processes by conducting external and internal audits. Regular testing ensures that your AML systems remain compliant with evolving regulations.