Criminals know how to get past your onboarding process. New customers are not necessarily who you think they are.
If you lack historical data and an overview of networks, or don't know which risk indicators are particularly important to you and your business, getting a clear picture can be very hard. Both right now and over time.
Be critical of your suppliers, make demands and tell them what YOU need. In this blog post we try to give you a basis for the questions worth asking.
What should I know that isn't common knowledge?
• If you are based in Norway and only screen against Nordic PEP and sanctions lists, you are not safe.
• Your risk is not the same as anyone else's; you should gather data from several sources and build your own model.
• Dynamic monitoring of your portfolio is essential. Once a year is far too little.
• You need go no further than Sweden before reporting some company data becomes voluntary.
• The difference between countries in how available data on beneficial owners is, is enormous.
• If you rely on international adverse media screening alone, the quality is often poor, because the underlying data on Nordic companies is missing.
• Brønnøysundregisteret carries out no ID check when a company is registered.
This means that a company can look perfectly safe, while there may still be current events, history, people and networks connected to the company you are dealing with that are questionable.
So if I have all the company information, do I have a full picture of the risk?
No. Having an overview of the profile of the customer you are dealing with is not enough either. Hopefully there will be a greater focus on types of transactions and the common denominators between them. Every transaction should be screened against, for example, currency, geographic area or other current and historical documents and registers, in order to identify the characteristics that may constitute risk.
Combining control of both the customer and the transaction will probably reduce false positives and irrelevant hits.
This may sound like a tall order, but the important thing is that you work out which transaction characteristics matter to you. Here, technology such as machine learning will probably be decisive in the future, making it possible to identify and connect alerts across vast volumes of data.
Are there other ways of collecting data than using public registers?
Many people also believe there should be a shared way of reporting findings and experience into a common database for everyone with a reporting obligation to Finanstilsynet. The fight against money laundering is, after all, not a competition, but something that demands genuine collaboration.
Blockchain technology has been widely discussed, but perhaps too little used so far. Could it be the solution here?
We all face the same threat, and we all share a responsibility to society to stop money laundering and terrorist financing with funds that flow through our banks.
Good data quality, new technology and the sharing of information will probably be decisive in stopping this kind of crime.
Where can I find out more about the challenges and solutions in anti-money laundering?
The webinar, a recording of which you can watch here brought together more than 100 people from the banking and finance sector.
The topic was Anti Money Laundering and how we can work together not just to do what we have to, but what we ought to.
Here are some of the best tips from AML expert Andreas Hobbelin at ZTL and lawyer Thor Dalhaug at PWC, for those of you who need to know your customer extra well.
