CASE STUDY 3
Money Laundering – closing the gaps
We assisted a large South African bank to meet the anti-money laundering regulatory requirements set forth by key authorities in respect of the Financial Action Task Force (FATF), which identified deficiencies in the country’s ability to combat money laundering and terrorist financing
Situation:
In response the Mutual Evaluation Report (MER) as set out by FATF, the client had to improve its anti-money laundering and financial crimes measures that suitably meet the requirements in a set timeframe. The primary objective was to assist the bank in achieving full compliance with AML regulations to address the FATF grey listing concerns.
Our Approach
We worked closely with the client to review potential gaps in adhering to the regulations and develop specific projects to adequately meet the requirements.
The key steps were:
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As-Is analysis – evaluated the bank’s existing AML policies, procedures, and systems specifically highlighted in the MER of 2022
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Internal Consultations - engaged with key stakeholders within the bank, including compliance officers, risk management teams, and IT personnel. This collaborative approach ensured a thorough understanding of the bank’s operational dynamics and compliance challenges
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Future design – created a comprehensive end-to-end design of the impacted processes to enhance efficiency, mitigate risks, and ensure seamless integration with existing operations. This phase was crucial for transitioning from the current state to a more efficient and risk-resilient future state
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Develop an Action Plan - conducted a comprehensive gap analysis to identify the discrepancies between the existing operations and the desired future processes. Based on this analysis, we created a high-level roadmap that provided a structured approach to achieving the transition effectively and efficiently.
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Implementation – worked closely with a cross-functional team to ensure that new processes were effectively integrated into the organization.
Results
Our client successfully developed and implemented risk mitigating processes that significantly reduced the potential for money laundering and proliferation financing, particularly in high-risk industries. These measures were designed to meet the stringent regulatory requirements outlined in the Financial Action Task Force (FATF) Mutual Evaluation Report (MER) of 2022.