Focus on: Financial Crime Conference 2022

With our inaugural financial crime conference fast approaching we wanted to share some more information regarding the event.

For Practitioners

All of us at Avyse have held industry roles and we’ve all been to financial crime conferences. Often we’ve been under-whelmed by the practical takeaways from conferences which have placed a large emphasis on macro policy with speakers drawn from public bodies far removed from the reality of attendees’ day jobs. The conference is an effort to challenge the status quo by bringing you a selection of discussions with relevant financial crime professionals that address real issues in a practical manner. In this blog we provide more information on three of the panels.

1.      How can MLROs and second line functions do more with less?

The expectation on MLROs continues to increase. On one hand we hear a lot about implementing a risk-based approach – but a truly risk-based approach likely means not doing certain activities in favour of focusing on the areas of greatest risk. However, by dropping certain activities MLROs open themselves up to regulatory censure as regulators have not subscribed to the risk-based approach in its truest sense. So MLROs and second lines are faced with increasing regulatory obligations and in many cases static headcounts. This panel will focus on how MLROs can work smarter and maximise the effectiveness of their function. Examples of questions that will be posed include:

• How are MLROs conducting their business wide risk assessments? Is this changing, and if so what are they focused upon? How are they making the process more efficient (taking less time to complete) and more effective (actually producing a useful, living document that addresses the real risks faced by the business)?

• How are firms approaching the periodic and trigger review processes? What methods are firms using to ensure that these controls are effective and efficient? Are there elements of these processes that firms have retired?

• What controls have MLROs identified as having little / no value in preventing financial crime and therefore have decided to significantly reduce resource / effort in these areas? And how are regulatory expectations being managed in these scenarios? Conversely which controls do MLROs think add most value and extra focus needs to be placed?

2.      With the Sanctions landscape often changing on a daily basis, how can firms confidently manage their sanctions exposure?

• What have firms found most challenging over recent times in terms of sanctions compliance – and how have they addressed these challenges?

• What have firms done to gain comfort that their sanctions screening solutions have kept pace with quickly changing requirements?

• How have firms managed their reactive efforts – understanding exposure to newly sanctioned individuals / entities, versus getting on the front foot and actively looking to understand how SDNs will look to circumnavigate sanctions and putting in appropriate controls and training?

3.      How do you navigate regulatory interaction without over-stepping the line?

• What is the best way to let the Regulator know you may have weaknesses in your financial crime control framework?

• How do you push back in the right way on Skilled Person report findings?

• What are the key things NOT to do if you disagree with the Regulator?