AML/CFT Regimes: Time for Implementation?

Je participe à la réunion du Groupe Egmont des Unités d’intelligence financière (UIFs) ou cellules de renseignements financiers (CRFs) qui se tient cette semaine à Monte Carlo (Monaco). Je suis extrêmement satisfait de noter une volonté de technologisation des opérations des CRFs et d’échange de renseignements sur le financement du terrorisme. Voilà, à mon avis, ce qu’il fallait faire depuis 10 ans et à l’Afrique de suivre !



I am participating this week (31 January – 5 February 2016) to the Egmont Group (EG) of Financial Intelligence Units’ Meetings in Monte Carlo, Monaco. The focus of the meetings in Monaco are the Working Groups (WG) with the emphasis on the new ones: Information Exchange on ML/TF, Membership, Support and Compliance, and Policy and Procedures.

The reorganization of the operating structure of the Egmont Group aims at helping the organization to be more effective to accomplish its mission of development, cooperation, and sharing of expertise between FIUs on money laundering but more importantly the emerging terrorist financing threats and vulnerabilities posed by terrorist fighters. For example, there is an increasing need for the exchange of information (especially non-classified information) between FIUs and other authorities involved in fighting terrorism.

One of these new WGs is the Information Exchange on ML/TF. Other new WGs cover activities related to (a) membership, support and compliance, (b) policy and procedures, and technical assistance and training.

I strongly believe that future technological innovations on AML/CFT will be likely influenced by the IEWG. Indeed, the IEWG would examine the synergies associated with the operational analysts and IT experts, to address the information exchange challenges faced by FIUs. The operational projects usually have a high level of IT element involved in them. The focus of the WG would be on increasing the quality and quantity of timely information exchange between FIUs based on operational and strategic analysis. Much of the work would be project oriented. The results of the projects would be shared, not only with members but also as appropriate, with observer organizations.

Time for implementation? Of course!

Many international legal instruments on AML/CFT are issued by various stakeholders: United Nations conventions, UN Security Council Resolutions, UN General Assembly Resolutions, FATF Recommendations, Fourth European Union AML/CFT Directives or Council of Europe AML/CFT Convention of 2005 (Warsaw Convention).

These legislations are essential if an AML/CFT regime is to have a solid foundation.  Now, the focus is much more on effectiveness. With emerging challenges both in countries with low capacity and in the most advanced and complex financial markets, effectiveness has moved to the top of all agendas.

Company registries, national police forces, anti-corruption agencies, customs authorities, secret services, regulatory agencies, national drug law enforcement agencies, intelligence agencies or the justice sector may play a central role in these processes. There is a need for these agencies and AML/CFT authorities to work together more closely to exchange information and take actions (including internationally) to prevent serious organized crime and associated money laundering/terrorism financing.

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