AMLMaps™ has been developed to give

the global Anti-Money Laundering

professional a singular, comprehensive

and easy to reference resource for AML

records, penalties & actions, from across

the world.

AMLMaps™ is currently in Beta Mode, as

our team of experts, researchers and AML

professionals continue to develop &

enhance its features with valuable inputs

& insights, given by users.

Please visit us at amlmaps.com

INTRODUCTION

AMLMapsTM FACT SHEET

This report covers critical global trends and highlights, by analyzing over 1300 validated AML records from the year 2000, for across the globe.

These insights have been created by AML experts at BMR Advisors by leveraging our work during the development of the largest known AML case repository - AMLMapsTM

HIGHLIGHTS

P

I

C

B

D

enalties have increased by over 20 times in the last 5 years, with no discernible signs of slowing down

ndividuals have been increasingly penalized, with a developing trend of convicting CEOs, Chairmen and other senior executives of implicated entities

ountries with the highest AML activity & records are USA (588), India (296) & UK (214). However, India continues to have one of the lowest penalties per AML action

FSI sector is expected to remain, the primary area of focus for AML regulators & agencies. Real Estate, Casinos & Gambling are an area of concern in the non-BFSI segment

eveloped regions continue to lead in terms of AML actions, as evidenced by the number of actions & penalties in North America & Western Europe

METHODOLOGIES & REASONING

Fraud, corruption, human trafficking & drugs feature prominently in the top methodologies, demonstrating the close linkage between these crimes & money laundering

Most actions due to Deficiencies in AML (121 cases) have been imposed by the Reserve Bank of India, in the absence of required features of AML programs, for Banks in India

Penalties ($13.1 Bn) for International Sanctions globally, are due to the enforcement of actions against enemy states of NATO and known terrorist organizations/entities

13,119

11,075

8,937

5,958

388 386 367 283 263 179

$0

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

Intern

ation

al Sanctio

ns V

iolatio

n

Tax Vio

lation

De

ficiency o

f AM

L Pro

gram

Inve

stmen

t Fraud

Secu

rities Fraud

Dru

g Trafficking

De

ficiency o

f KYC

No

rms

Co

rrup

tion

Mo

ney Lau

nd

erin

g

Finan

cial Fraud

Mill

ion

s $

Penalties Across Top 10 Methodologies

57

38

1

9

47

5

40

5

38

1

23

10

36

11

-10 50

REGULATORS

USA specific AML records demonstrate the extensive activity of multiple regulators, bodies & agencies, who work in coordination and at times compete towards pursing AML actions

RBI is the single most active regulator in terms of actions. However, low cumulative fines & penalties ($17 Mn) indicate that these have been preventive rather than punitive in nature

The average penalty imposed by US regulators has been $34 Mn v/s the global average of $26 Mn

At least 6 nations have implicated entities of other nations in AML actions. USA is responsible for most of these, which is evidence of their intent & capacity for extra-territorial reach

U.S. District Court of New York - USA

FINTRAC - Canada

Office of Foreign Assets Control (OFAC) - USA

Financial Services Authority - UK

Other U.S. Authorities - USA

National Crime Agency - UK

Board of Governors of the Federal Reserve System - USA

Financial Industry Regulatory Authority (FINRA) - USA

U.S. District Court of Washington - USA

Internal Revenue Service (IRS) - USA

New York State Department of Financial Services - USA

Serious Fraud Office (SFO) - Ghana

U.S. Department of Justice - USA

Reserve Bank of India - India

Financial Crimes Enforcement Network (FinCEN) - USA

$0.41 Bn

$0.002 Bn

$1.48 Bn

$0.07 Bn

$2.5 Bn

$0.02 Bn

$5.01 Bn

$0.06 Bn

$5.9 Bn

$0.3 Bn

$6.28 Bn

$8.4 Bn

$5.09 Bn

$0.02 Bn

$1.67 Bn

287

Actions by Regulators

Cumulative FinesNo. Of Records

BFSI

BFSI entities (~70% banks) by virtue of being at the center of AML norms & actions, have attracted more than 60% of the total penalties

AML actions against Banks constitute 50% of all records but around 75% of all penalties. This clearly reaffirms the status of Banks being most at risk, by AML regulators.

A number of FIs charged with breaching money laundering norms are alleged to have leveraged correspondent relationships. The penalties in these cases have been in excess of $12 Bn

Only 3% of AML records in the BFSI sector are related to Tax Heavens. This showcases their inability or unwillingness to take the appropriate AML actions, as are being demanded globally

636

521

67

$25,374 Mn

$7,870 Mn

$8,685 Mn

BFSI

Individuals

Non BFSI

324

35

10

45

222

$17,821 Mn

$6,210 Mn

$807 Mn

$263 Mn

$272 Mn

Banks

Financial Services

Investment Banking

Money Services Business

Others

No. of Records

Penalties

PenaltiesNo. of

Records

BFSI v/s Individuals v/s Non-BFSI

BFSI Only

NON-BFSI

$8.4 Bn penalty has been for a single case in the Telecommunications* sector and no other prominent case has been reported for this sector

Real estate is the most fined sector with 60% of the fined entities being based out of UK, primarily due to stringent fair trading and anti-corruption laws

In over 40% of records for Non-BFSI entities, deficiencies in the AML program have been the reason for fines, demonstrating the expectation of an effective AML program, beyond BFSI

$175,050 K

$40,200 K

$18,037 K

$12,400 K

$7,464 K $7,039 K $3,255 K $1,797 K $465 K $344 K

9

1

4

1

2

3 3

4

10

4

0

2

4

6

8

10

12

$0 K

$50,000 K

$100,000 K

$150,000 K

$200,000 K

Re

sorts an

d C

asino

s

Ch

em

ical

Co

nsu

me

r Staples

No

n P

rofit O

rganisatio

n

Engin

eerin

g and

Co

nstru

ction

Tou

rs and

Travels

Health

Care

Gam

blin

g

Re

al Estate

Re

tail

Penalties & Actions for Non-BFSI Entities

Cumulative Penalties No. of Records

* Telecommunications has been kept out of the scope to draw a more relevant comparison between the sub-sectors

REGULATORY ACTIVITY POST 9/11

With roughly 40% of the total global actions, US regulators (collectively) are leaders in imposing the highest number of AML actions & penalties

Post 2012 there has been an acceleration in the number of recorded AML cases, making up to 85% of the total records between 2000-15.

Only 3% of the AML cases are due to lack of AML awareness, limited co-ordination between federal agencies and nascent compliance technologies between 2001-05

The causes being the acceleration of AML actions are - technological advancements, on-ground activation of laws by regulators/agencies, enhanced global cooperation & coordination and pressure on tax havens & equivalent regimens

With the exception of 2007, which showed a jump in the value of penalties, there has been a steady acceleration in the number of actions. This trend is expected to continue.

$10 Mn $6 Mn $38 Mn $29 Mn $171 Mn $15 Mn

$8,522 Mn

$84 Mn

$999 Mn $556 Mn

$65 Mn

$9,483 Mn

$1,920 Mn

$6,418 Mn

$12,970 Mn

$643 Mn

2 4 5 9 1117

1119 21

58

124

82

160

263 291

147

-30

20

70

120

170

220

270

320

$0 Mn

$2,000 Mn

$4,000 Mn

$6,000 Mn

$8,000 Mn

$10,000 Mn

$12,000 Mn

$14,000 Mn

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Year Wise Penalties & Actions

Total Penalties No. of Records

INDIVIDUALS

Over 30% records involving incarcerations are pertaining to drug trafficking, re-emphasizing the intricate relationship with money laundering & the predicate nature of this crime

USA has been the leader in convicting individuals for money laundering followed by UK, Malaysia, Thailand & Hong Kong

Former Chairman of Board along with Founders have been one of the most convicted professionals amongst individuals. This trend is expected to continue & grow.

Incarcerations have increased post 2012, reflecting the intent of regulators to establish personal liabilities on individuals, even for organization centric AML actions

2 1 2 2 5 6 8 11 17 20

52

170 165

89

2002 2003 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Records Involving Incarcerations

Former Chairman of Board

Chief Compliance

Officer

FounderChief

Operating Officer

Owner

Former President

Former Prime Minister

Former Chief Executive Officer

President

Chief Executive Officer

REGIONAL ANALYSIS

With over 40% of records and cumulative penalties, North America is the global leader, amongst regions, in enforcing AML norms and regulations

For Latin America, Oceania & Asia most of the penalties have been imposed post 2010, due to increase in AML awareness, mutual assistance & technological advancements

Although Western Europe seems to be fairly active, barring the UK, all the other countries contribute to only 10% of total records, for the region

Eastern Europe, Middle East & Africa constitute for only 5% of the total AML records, showcasing weak AML compliance norms despite having criminal & terrorist activities

$8,418

$290 $1 $887

$123

$17,275

$5 $25

$14,860

Africa Asia Major EasternEurope

LatinAmerica

Middle East NorthAmerica

Oceania South Asia WesternEurope

Penalties ($Mn)

1537

1148 34

505

9

302

257

Africa Asia Major EasternEurope

LatinAmerica

Middle East NorthAmerica

Oceania South Asia WesternEurope

No. of Records

Sarabjeet SinghPartner Risk & Advisory Services

SARABJEET SINGH is a Partner in the Risk and Advisory Services practice at BMR and is an expert in the Banking and Financial Compliances and Utilities Finance

Systems, having spent over 9 years working on State Electricity Board clients. Prior to joining BMR in 2006, he worked for nine years at Arthur Andersen and a

further 3 years at Ernst & Young. He has over 21 years’ professional experience, delivering a wide range of services in accounting, due diligence reviews,

internal audit, financial reporting processes, solution development and analytics.

Sarabjeet has also been primarily involved in assurance reviews and audits of large multi-location clients, formulating and implementing financial accounting

packages, policies and practices, operational and financial controls review and financial systems related fraud investigations. He has extensive experience in

AML/KYC matters across geographies and has implemented global AML/KYC solutions for large financial institutions and multinational banks.

Partner with consulting experience in Anti-Bribery, Anti-Money Laundering & Data Services

ABHISHEK BALI has over 8 years of experience in areas related to Anti-Money Laundering, Anti-Bribery, Third Party Risk, Online monitoring and Data Services.

He has assisted clients with developing data assets, executed AML Reviews for foreign clients, deployed third party risk solutions and contributed in global

outreach exercises. He has also assisted Startups and High-growth companies in coming to terms with their Risk Management practices

His other areas of work are related to Supply Chain - Risk Consulting, Risk Management Programs, Enterprise Risk Management, AML, Social Listening and Due

Diligence. Abhishek has managed and carried out projects for clients across industries like Oil & Gas, Manufacturing, Technology, Banking, Automobile, Heavy

Engineering, Startups, Cement, Private Equity, Venture Capital & Hospitality.

Senior Vice President with experience in Financial Crimes Compliance and Data Assets

Abhishek BaliSenior Vice PresidentRisk & Advisory Services

THE TEAM

The information contained in this document is for general information purposes only. While the firm endeavors to keep the information up to date and correct, we make no representations or warranties of any kind, express

or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the document or the information provided therein. All information contained in this document may be acquired from publically

available sources and hence any reliance you place on such information is therefore strictly at your own risk and the firm accepts no liability in relation to the use of the document. The firm reserves copyright of this

document and hence, does not allow anyone to sell, re-publish or re-distribute the document or derivatives thereof.

© Copyright 2016, BMR Business Solutions Pvt. Ltd. All Rights Reserved

Sarabjeet Singh

Partner

+91 124 669 5044

sarabjeet.singh@bmradvisors.com

Abhishek Bali

Senior Vice President

+91 124 669 5033

abhishek.bali@bmradvisors.com

Please visit us at amlmaps.com