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AUSTRAC argues there are business benefits in AML compliance

I recently discussed whether there is value in compliance? Do you really need to present a business benefits case to implement a compliance program required by law?

It's been commonly accepted that AML is one compliance program where implementation is an obligation (ie satisfying regulatory requirements) and cost with little business opportunity.

But in recent presentations, AUSTRAC has argued that regulated entities can create value by managing ML/TF risk:

  • Investing in ML/TF risk management creates value by addressing the following risks of damage or destabilisation to vital Australian financial assets:

1. Sovereign risk – compromising Australia’s international standing as a safe financial centre with a sound institutional infrastructure.
2. Horizon risk – favouring potentially transient short-term gains over the entity’s long-term best interests.
3. Reputational risk – damaging the commercial value of the brand name.

  • Substantially upgraded ‘Know Your Customer’ and increased record retention obligations are costs –but are also more than just burdens. In organisations which do not yet have tools to present a single customer view (eg are account based rather than customer based) the cost of the new KYC programs will have spin off marketing and cross-selling benefits.

What other benefits are there in an AML program that might represent cost savings?

  • Although AML and fraud detection use different techniques, there may be fraud detection benefits especially in connection with "politically exposed persons".
  • The program may be the basis for a consistent approach to a range of problems group-wide.

In any case, AML, like any other compliance obligation, requires careful implementation project plannning. If other benefits can be identified, all the better.

May 25, 2007 in Anti-money laundering | Permalink

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Comments

David,
One possible benefit comes from the requirement to know your customer better. If you know your customer well enough to pick up a change of behaviour for AML purposes you have a good chance of picking up changes that present marketing opportunities. For example, a large transfer from overseas may be money laundering or it could be an opportunity to sell financial planning services.

Posted by: Andrew | May 27, 2007 1:40:29 AM

Thanks Andrew
The extent that information obtained for AML purposes can be shared between entities in a group will be limited by privacy issues.

Even within an organisation, you need to be careful to alerting a customer they are being monitored in case their activity is unlawful.

Subject to those limitations, the marketing benefits will depend on the type and size of organisation and where it is now: an organisation that has a sophisticated data mining system already in place will argue that a new AML system is of no additional marketing use but an organisation that is smaller and does not have a dedicated CRM system may be able to get spin off benefits from a new AML system.

Separate from the technology there will be staff training issues: getting staff to better know the customer for compliance purposes should not just be a form filling exercise but an opportunity for custonmer service officers to generate discussion about the customer: who they are (if they are a "politically exposed person" they may know other people who could become customers), the sort of transactions they might have in the future, what they do (which industry they are in), which other countries/parts of Australia they do business with or have relatives in etc. And then the CSO might be able to cross-sell services but at least will have sufficient data to assess AML risks.

The starting point is the basic legal requirement for an organisation to consider the risk posed by the following factors:
(1) its customer types, including any politically exposed persons;
(2) the types of designated services it provides;
(3) the methods by which it delivers designated services; and
(4) the foreign jurisdictions with which it deals.

Whether and how an organisation can leverage that requirement is something that needs to be considered on a case by case basis.

David

Posted by: David Jacobson | May 27, 2007 6:32:55 AM

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