The New Focus, Not the Only Focus
I am often asked about a trending predicate offence, the new focus in compliance or main concerns in the industry. For example, cryptocurrency and virtual assets overall have peaked the interests of many individuals looking to transition into this increasingly popular field; FinTech was trending a few years ago and is picking up speed again; there is a lot of emphasis on crimes revolving around human trafficking and wildlife trafficking, which unintentionally overshadows other crimes and misleads many. As a regulatory compliance consultant, it is essential that I remain up to date on trending concerns.
The very interesting thing about compliance is that it is extremely extensive and almost limitless in its scope. In my view, the anti-money laundering program is the base, the standard, the initial step for consideration and implementation for complying with recommendations, regulations, guidelines and more as it relates to AML compliance. The emerging “trend” of a particular crime is meant to ensure that your program highlights and specifically identifies the potential of this crime of presenting a risk to the organization. To put it a different way, the AML program is meant to manage the validity of clients, third parties and others as safe for an organization to engage with. The consideration of a specific predicate offense such as human trafficking, drug trafficking, tax evasion and so on is to ensure you’ve identified the potential risk of being infiltrated by such a crime. In doing so, you must not be blinded in thinking, such crimes could never grace your door.
Think of that person, you know the great boss, the wonderful significant other, the angel of a child you raised and now think of that moment when they betrayed your sincere belief in them. Scary right? People often present their best selves to achieve an objective, others change over time and still, others don’t even realize what they did wrong, leaving you to face judgement for your trust in them.
This is why it is extremely important to maintain a high degree of integrity in your AML program and consider every potential crime and validity of those you engage with not only at the onboarding stage but throughout the life of the relationship. Take into consideration not only the trending crime but all crimes that have the potential to infiltrate your industry or country. Often when multiple projects are overlapping, firms engage a regulatory compliance consultant firm to assist with managing projects and ensure accomplished by a desired deadline.
Famous last words: I’d never work with a criminal. But she had such a nice smile and pleasant personality. I’ve known him for years. Terrorists don’t come to my country, I’ve never seen one.
