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Invite colleaguesThe new era of anti-financial crime compliance
Abstract
Following the Panama Papers and to a lesser extent the Bahama Papers scandals, a number of persons, physical and legal, have been revealed as potentially exposed in corruption and/or other forms of money laundering activities. This scandal was a reminder of the need for an enhanced antifinancial crime framework encompassing enhanced due diligence, identification of beneficial ownership, assessment of third party risks and hyper-analytic tools and systems to enable effective risk monitoring in all financial institutions. This paper presents the current measures imposed by the European Union regarding customer due diligence, beneficial ownership, reliance on third parties, continuous monitoring of accounts and transactions, proposed amendments under consideration aiming at further strengthening and enhancing the existing framework and the view of the author that a cultural transformation of Financial Institutions and the incorporation of anti-financial crime activity into their daily operations will successfully apply the lessons learned from the Panama Papers. An effective anti-financial crime function is no longer a checklist of regulatory obligations or list of rigid rules and procedures but rather a corporate culture built on ethos. Its effectiveness is measured not in terms of the degree of conformity to the vast amount of regulatory frameworks in place but rather on the degree of integrity and clarity that corporations adopt in a practical sense.
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Author's Biography
Marios M. Skandalis is a fellow member of the Association of Chartered Certified Accountants (UK), a licensed member of the Association of Certified Fraud Examiners (US) and a Certified Financial Consultant. He is a Fellow member of the International Compliance Association of the United Kingdom and member of the Society of Corporate Compliance and Ethics of the United States of America. Today he is Director of the Group Compliance Division of the Bank of Cyprus Group. Skandalis’ professional career began in 1995 when he served as an Audit Supervisor and a Senior Management Consultant with Ernst & Young in the South- Eastern European region. In 2000 he moved to the Bank of Cyprus Group and took the post of Chief Financial Officer of the General Insurance of Cyprus for over a decade before becoming manager of the Organisation of the Bank’s Overseas Operations until 2013 when he was appointed legal representative and head of the Bank of Cyprus’ operations in Greece. Marios is the vice-president of the Institute of Certified Public Accountants of Cyprus, Executive Vice- Chairman and founder member of Transparency International (Cyprus) and vice-president of the Association of Certified Fraud Examiners (Cyprus Chapter). He is an active anti-fraud/ corruption and compliance professional and chairs or participates as key note speaker to related international conferences/forums in Europe. Marios M. Skandalis is also the winner of the 2016 Banker of the Year Award – Cyprus by AI Magazine in the UK.