permanent tsb is a significant provider of retail financial services in the Irish domestic market. One of its strategic objectives is to ‘Embed a Values-Based Culture’ across its business, and given this strategic objective, the Group Money Laundering Reporting Officer (MLRO) wanted to focus specifically on the Anti-Money Laundering (AML) culture. The key challenge that permanent tsb faced was how to assess something as nebulous as AML culture and do so in an efficient and cost-effective way.
In 2017 one of Ireland’s pillar banks embarked on a regulatory change management programme which was intended to deliver an enhanced and improved Financial Crime Compliance (FCC) framework across multiple jurisdictions which was robust, efficient and sustainable into the future for all newly emerging threats. The new FCC framework design incorporated a strategy to embed the appropriate behaviours and attitudes required to deliver a sound culture for AML.
In 2015 an acquisition focused investor group acquired a bank with operations in six countries, several of which rank amongst the fastest growing countries, by GDP, in the world. The investors needed to quickly assess the compliance competency and technology capabilities of their new acquisition, particularly as it related to US regulatory requirements.
A US based consulting company with a global team of experienced security and technology consultants, and compliance and monitoring experts, was retained to carry out the compliance review. They worked in conjunction with Mizen Group, a Boston based company specializing in Anti-Money Laundering (AML) compliance, to undertake the AML elements of the assessment. Mizen was tasked with executing a full AML compliance operations and technology assessment in a compressed timeframe. To deliver within these constraints Mizen needed to accelerate the assessment process while ensuring consistency across the six different regions. In summary, Mizen needed to find a way to simultaneously assess an extended bank network in six separate countries to identify AML compliance trouble spots, and to diagnose the degree to which a robust AML culture was embedded in the operations in the various countries.
This white paper briefly describes what money laundering is, how it originated, and some of the techniques that money launderers routinely employ.
This white paper briefly outlines Irish banks’ responsibilities for identifying and reporting known or suspected cases of money laundering or the financing of terrorism.
A review of money laundering costs and penalties
This white paper briefly describes some of the costs and penalties that financial institutions have incurred in trying to prevent money laundering or as a result of breaches of money laundering and terrorist financing legislation.