Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.
– Integrating KYC Information and Transaction Monitoring – Growing expectations for Comprehensive Client Reviews across businesses and geographies – Increased expectations regarding depth and breadth of periodic reviews – KYC and the 4 F’s FATF, FinCEN, FFIEC, FATCA Hot Topics in AML
– Client risk score/ratings and profile information driving monitoring treatment – Monitoring activity driving KYC profile updates – Monitoring history influencing client risk score/ratings – KYC profile details, anticipated activity, expected volumes, etc, leveraged in alert investigation Integrating KYC Information and Transaction Monitoring
– Growing expectations for KYC programs to profile clients across businesses and geographies – Challenge of identifying and linking all client entities and accounts in a common profile – Data protection and privacy requirements may limit the flow of information for these purposes – Increasingly complex requirements for client relationships with multiple related parties and accounts. – In these circumstances, determining who owns the relationship, what KYC requirements apply, and how they will be satisfied on an ongoing basis Growing Expectations for a Comprehensive Client View
Ongoing Due Diligence / Periodic Reviews – Expectations regarding depth and breadth of periodic reviews Update of KYC profile information and data Actual vs. anticipated activity Detailed transaction reviews Investigations and alert activity – Trigger events vs. periodic scheduled reviews – Targeted high risk client reviews – Orchestrating cross-border and/or cross-business periodic reviews
KYC Programs and FATCA – Navigating through complex international requirements (FATF vs. regulatory expectations in key markets vs. FATCA) – FATCA, FATF, FinCEN and FFIEC effect on beneficial ownership requirements globally – Classification of existing clients under FATCA and documentation remediation – Potential practical issues and consequences