Anti-money laundering, know your customer, and curbing the financing of terrorism

Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations are complex issues that require concerted action across all market participants; including banks, supervisory authorities, payment schemes and the international community. They all have a role to play in addressing the issues that have given rise to the phenomenon known as ‘de-risking’, which has seen banks closing accounts and exiting markets in order to reduce their exposure to regulatory enforcement action, in preference to managing the risk.

This is according to a new report, entitled “Anti-Money Laundering, Know Your Customer and Curbing the Financing of Terrorism”, published today by the Financial Sector Deepening Africa (FSD Africa) in partnership with Consult Hyperion. The report concludes that the need for financial service providers to pursue a comprehensive approach to due diligence (of both customers and of commercial partners) and AML is greater than ever.

It recommends that the Financial Action Task Force (FATF) -defined Risk-Based Approach (RBA) should be embraced in collaboration with national regulatory authorities.  Without full backing for the RBA from these authorities, and – in most cases – their counterparts in the US, there is a risk that financial institutions will continue to withdraw their services from particular markets and take refuge in ‘de-risking.’

Commenting on the report, Paul Makin, the Head of Financial Inclusion at Consult Hyperion, says: “The areas of money laundering and KYC are complex and multi-faceted, with many interlinking issues and unexpected consequences. This report demystifies the subject, and presents a coherent view of how we got here; why banks choose to withdraw from markets for particular groups of customers, how this came to be characterised as ‘de-risking’, and what can be done about it.”

The report concludes that with the continuing terrorism threat, attention should be paid to anonymous transactions which disburse cash. Robust Customer Due Diligence (CDD) processes at banking or mobile money agents must be enforced. Whilst some elements are technical (for example, biometrics, transaction limits, bearing down on cash, etc.), others will be in the areas of organisation and co-operation, particularly around the sharing of transaction and registration data.