The United Kingdom’s National Crime Agency (NCA) has issued an AMBER alert in respect of South Sudan.
Getting the balance right is as important as closing our doors on illicit financial flows. Blanket application of risk policy may be the easier approach when drafting customer acceptance criteria but that approach can also contribute to deepening the poverty imbalance in jurisdictions where the people are suffering at the hands of their leaders.
Robust risk assessments that seek to understand the risk posed by the individual customer are vital if we are to identify and disrupt corrupt practices but also to ensure that the vital help and legitimate investment can continue to flow into affected regions to alleviate the suffering of the people.
AML is more than just box ticking, it is a difficult balance of consideration of all the risk factors, mitigating actions and controls to make an informed decision of the risk posed by the business before you. These decisions are not easy and in many cases require an open and enquiring mind to understand what the information and intelligence is telling you. That is why compliance is undertaken by trained professionals with appropriate standing in their business and a deep seated knowledge of their industry. These decisions are not just about regulatory compliance or whether the company can write the business, there is also a very real human impact as each decision made can make a real difference to real people.
I have never seen this message as strongly emphasised in a publication of a law enforcement agency than in the latest NCA Amber warning concerning the South Sudan.
Here at Rowany AML Solutions Limited we can provide an independent evaluation of the customer and business risk assessment processes and procedures. Give us a call to arrange a chat about how we might be able to help you.