Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.
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Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.
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Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc. Hot Topics in AML. Integrating KYC Information and Transaction Monitoring Growing expectations for Comprehensive Client Reviews across businesses and geographies - PowerPoint PPT Presentation
Transcript of Pamela J. Johnson Managing Director, Global Head, AML & Sanctions Compliance Citigroup Inc.
Pamela J. JohnsonManaging Director,
Global Head, AML & Sanctions ComplianceCitigroup Inc.
– Integrating KYC Information and Transaction Monitoring
– Growing expectations for Comprehensive Client Reviews across businesses and geographies
– Increased expectations regarding depth and breadth of periodic reviews
– KYC and the 4 F’s FATF, FinCEN, FFIEC, FATCA
Hot Topics in AML
– Client risk score/ratings and profile information driving monitoring treatment
– Monitoring activity driving KYC profile updates
– Monitoring history influencing client risk score/ratings
– KYC profile details, anticipated activity, expected volumes, etc, leveraged in alert investigation
Integrating KYC Information and Transaction Monitoring
– Growing expectations for KYC programs to profile clients across businesses and geographies
– Challenge of identifying and linking all client entities and accounts in a common profile
– Data protection and privacy requirements may limit the flow of information for these purposes
– Increasingly complex requirements for client relationships with multiple related parties and accounts.
– In these circumstances, determining who owns the relationship, what KYC requirements apply, and how they will be satisfied on an ongoing basis
Growing Expectations for a Comprehensive Client View
Ongoing Due Diligence / Periodic Reviews
– Expectations regarding depth and breadth of periodic reviews• Update of KYC profile information and data
• Actual vs. anticipated activity
• Detailed transaction reviews
• Investigations and alert activity
– Trigger events vs. periodic scheduled reviews
– Targeted high risk client reviews
– Orchestrating cross-border and/or cross-business periodic reviews
KYC Programs and FATCA
– Navigating through complex international requirements (FATF vs. regulatory expectations in key markets vs. FATCA)
– FATCA, FATF, FinCEN and FFIEC effect on beneficial ownership requirements globally
– Classification of existing clients under FATCA and documentation remediation
– Potential practical issues and consequences
