1. DEVELOPING AN EFFECTIVE AML REGIME – KEY CHALLENGES AND RESPONSES
Mike Trigg
Group Head Financial Crime Risk

2. Standard Chartered Bank A Challenging Risk Matrix
Over 50 countries
Diverse emerging markets
Wide range of financial services

3. Keeping Pace with a Changing Regulatory Environment
Spread of legislation and regulation
Changing regulatory expectations
More proactive enforcement
More players (FAFT / IMF / Wolfsberg)

4. Local versus Global Variations between local requirements
Parent v local regulator
Local competition
Extra-territorial issues (Correspondent Banking, Offshore Booking,Sanctions)

5. Response – 6 Point Programme
Stakeholder Engagement
Roles and Responsibilities
KYC
Suspicious Activity Reporting
Training
Monitoring

6. Stakeholder Engagement
Parent Regulator
Local Regulators
Inter-Government Agencies
Industry Groups

7. Roles and Responsibilities
Country Managers
Business line
MLRO structure

8. Know Your Customer Risk based approach Mandatory Group standards
Approved local gap analysis
New accounts
Existing accounts (risk based)

9. Suspicious Activity Reporting
Internal Reporting (automation?)
External Disclosures
Local challenges

10. Training Computer based (key messages, measurable, cost effective)
Specialised management programmes
Specialised product programmes

11. Monitoring Ongoing risk assessment In-line quality assurance
Compliance risk monitoring
MLROs
Audit