AML/CFT: Lessons (hopefully) learned, and the coming sea change

18/03/2025: 09:00 – 14:30

Part 1: Lessons (hopefully learned): The recent cases that made the headlines

TD Bank: the largest fine ever imposed in the US

·       The early signs.

·       Where was compliance and the AML function?

·       Governance slept at the wheel? Anyone with AML background at the Board?

·       Remediation and accountability.

Bank of America: Even the best can fail

·       Suspicious Activity Reports: the usual suspect

·       Client Due Diligence programme: does it do the job?

·       An Action plan is needed.

Robinhood case: Not such a straight arrow

Metrobank case: Automated Transaction Monitoring Systems in AML: not a silver bullet

Starling Bank case: Client growth is great (that is, if your obliged entity’s financial crime controls can keep up).

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Part 2: The sea change of the EU Regulation on the prevention of the use of the financial system for ML/TF (2024)

·       The need for change

·       The Fourth EU AMLD, turbocharged: a broad view of the upgrades

·       The risk variables, repopulated.

·       An old-times favorite, revisited: Third countries and high-risk. Bringing things in line with FATF (almost).

·       The Compliance Manager:  the buck does not stop here.

·       Beneficial owner registration for risky foreign legal entities. What does this have to do with us?

·       PEPs: some tidying up is in order.

·       Beneficial owner identification: the next frontier.

·       Enhanced due diligence: NOW you are talking.

·       Higher risk factors: Anyone said anything about non-face-to-face business relationships?

·       Suspicious activities and transactions: Assistance is coming.

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AML/CFT is a dynamic, fast changing field, aiming to analyze or respond to new threats and typologies. Our training programmes are designed to bring you the latest important developments and our programme content may be revised closer to the date as necessary; so as to reflect new laws, case studies, procedures, and other important recent developments.

This programme has been developed by professionals for professionals in the legal, financial, accounting/audit, and corporate administration fields who already have a basic understanding of the current AML regulatory system:

·       Legal professionals,

·       Auditors/Accountants,

·       Risk Managers,

·       AML Compliance officers of Obliged Entities (regulated financial institutions including credit institutions, investment firms and fund managers, administrative service         providers and others),

·       Board members of financial institutions responsible for the implementation of AML/CFT law and regulations.