📢 What trigger an escalation from AML/CTF 1LoD to 2LoD?
➡ You are recently hired within the Bank's client #onboarding Team (#1LoD) and a week later your line-manager is asking you when an escalation to the Compliance Function (second line of defense (#2LoD), is essential.
⚠ Certainly, coherent and clear policies and procedures should govern and set the pre-determined cases and situations where an escalation is needed, in the absence of, the #Compliance Program is deemed inadequate or insufficient. As a result, here is the answer to your line-manager:
1️⃣ Unusual or Suspicious Activity:
▶ Transaction Monitoring #Alerts: When the #1LoD identifies transactions or patterns of transactions that deviate significantly from a customer's known behavior or established norms.
▶ Customer Due Diligence (#CDD) findings: Issues identified during the on-boarding or on-going monitoring processes that suggest potential money laundering or terrorist financing risks.
2️⃣ Thresholds:
▶ Transaction Amounts: Transactions exceeding certain pre-defined monetary thresholds that require additional scrutiny from #2LoD. For example, transactions exceeding the amount of €100K.
▶ Risk Scores: Customers or transactions that score above a certain #risk threshold during risk assessment processes. Usually, #highrisk clients are escalate to the Compliance Function, regardless of other aggravating risk factors.
3️⃣ Adverse Media or Information:
▶ Negative News: #newsreports or other #media indicating potential involvement of an existing or new customer in illegal or criminal activities.
▶ #Sanctions or Watch-lists: Hits against financial restriction measures or sanctions lists, or other regulatory watch-lists.
4️⃣ High-Risk factors or indicators:
▶ Geographical/country risks: Involvement of high-risk #jurisdictions in transactions. These, shall include #taxhaven jurisdictions, #sanctions related or countries with insufficient ML/TF preventive measures, etc.
▶ Client risks: Involvement of high-risk clients (e.g. #PEP’s) or sectors known for higher ML/TF risks.
5️⃣ Patterns or Trends:
▶ Behavioral Patterns: Emerging patterns or trends in transactions that indicate potential #moneylaundering or #terroristfinancing activities.
▶ New Typologies: Identification of new typologies or methods used by criminals that necessitate closer examination. For example, a criminal start using a holy-monastery bank account to launder the proceeds of his drug-smuggling business ❗ .
6️⃣ Customer risk re-assessment:
▶ Periodic Reviews: Scheduled reviews of customer profiles and transactions that reveal new or increased risks. For example, for high-risk clients, during the yearly update, a new #riskfactor emerges needed to be examined from #2LoD.
▶ Trigger Events: Significant deviations of customer’s expected business activities or behavior prompting a re-assessment of #residual risk.
SAVP, Senior Financial Crimes Specialist @ Wells Fargo | CAMS, CFCS
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