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Abstract
Antimoney laundering (AML) and antibribery and corruption (ABC) programmes, by themselves, are important tools in addressing problems that are global in scope. While AML and ABC programmes are distinct, they also entail complementary skills, which reflect the nature of the financial crimes they are designed to prevent. Although AML and ABC programmes have historically operated independently, it no longer makes sense to perpetuate that separation. AML and ABC can, and should, collaborate to enhance their effectiveness. The challenges facing AML and ABC programmes are numerous and sizable. Many financial institutions, particularly domestic regional or community banks, must manage the expense of compliance and limited resources, in terms of skilled staff as well as budgets. Nevertheless, they must recognise an immutable fact: the cost to prevent financial crimes is a fraction of the cost to remediate them. The stakes in AML and ABC have never been higher, but there are ways to mitigate the risks of both today and tomorrow. Institutions can strengthen their compliance programmes by aligning their AML and ABC teams. This paper will discuss the challenges ABC and AML programmes have historically faced, and provide tangible solutions for bringing the two verticals together to create efficiencies and enhance the efficacy of entities’ financial crimes compliance programmes.
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Author's Biography
Michelle Goodsir recently served as a managing director within the Financial Crimes Risk and Compliance practice at K2 Intelligence FIN Integrity Network, a global risk advisory firm. Her 25 years of financial services industry and US Government experience spans anti-bribery and corruption (ABC), fraud risk management, corporate security and investigations, sanctions, anti-money laundering (AML) programmes, and compliance programme builds, operations, analytics, and business intelligence. Before joining K2 Intelligence FIN, Michelle was managing director and global head of ABC and fraud for a European bank and she also served as managing director and head of global cross-sector AML operations at Citi. She began her career as an analyst for the Central Intelligence Agency, where she worked on global money laundering issues and produced analytical reports on bribery, organised crime and illicit finance. Michelle currently serves as Chief Ethics Officer for the Americas for Sumitomo Mitsui Banking Corporation.