28th February 2024: AML Compliance System Optimisation

Context:

AML regulation has been incorporated in compliance program for decades. In recent years the tendencies of governments to tighten the net around tax avoidance practices and the increased use of economic sanctions have translated in a significant increase in regulatory scrutiny and compliance requirements. This increase in compliance risk also stem from legacy compliance programs designed to achieve general compliance objectives (KYC, anti-fraud, governance, etc) that only partially overlap with the control level demanded by a robust AML compliance program, leaving gaps in some cases (where MLRO stretched existing programs) and inefficiencies in most (where bolt-on procedures were inserted to satisfy regulation).

Objective of the course:

The course will start top-down from the Financial Action Task Force (FATF) recommendations and guidelines to systematically review the designing and implementation of an AML compliance function that both complies with current AML regulations and avoids creating bottlenecks in the ongoing business activities of a financial institution. Many times, such bottlenecks or challenges result in a fragmented framework of policies, leaving behind several dead-end procedures with limited efficacy in achieving the organisation’s overall AML objectives.

Training outline:

• Current AML regulation and its objectives
• FATF recommendations (Inherent Risk and Controls)
• AML compliance program in theory
• AML compliance program in practice:
  • Assessment
  • Redesign
  • Transition Plan
  • Implementation
• AML role of non-compliance staff

Subject matter expert: Emanuele Cibrario, Independent AML & Risk Consultant, Italy

Emanuele is an experienced professional in the fields of regulatory compliance with a long-term career with the UAE financial markets regulator where he was a senior inspector in the AML supervision department (hence the top-down approach in his lecture).

As the main data analyst in the AML department, he has developed a variety of financial models and risk assessment tools. Over the years he has acquired different competencies in risk management, economics, and especially AML.  Having started his career in investment banking in London in 2005 structuring credit derivatives and asset-backed securities, he brings a strong analytical and quantitative approach to these subjects. He is fluent in VBA for Excel and machine learning packages in Python and, most importantly, has learned to render these languages in English when presenting findings and assessing a model’s performance. Emanuele graduated from the ESCP-EAP in Paris, holds a Laurea in Economia Aziendale from the University of Turin (Italy), he is a CFA charterholder, has FRM certification from the Global Association of Risk Professionals, and he is an ACAMS certified AML specialist.

Who should attend:

The attendees are expected to be familiar with key terminology and have a basic understanding of compliance programs. This lecture could be interesting for compliance professionals seeking to shift focus on AML tasks. The ideal target audience is AML professionals looking to optimize their AML compliance program, while also gaining an insight from the perspective of regulators.