Implementing an Effective Anti-Money Laundering System


The investigation and prosecution of money laundering has changed dramatically in recent years. In 2012 record-breaking fines issued by regulators worldwide dominated the financial services landscape, a trend which looks set to continue through 2013 if regulators identify further failings in firms’ compliance with money laundering, sanctions and tax requirements.

Although financial institutions have had anti-money laundering (AML) and economic crime control programs for some time, many still do not have sustainable, cost-effective processes in place, Senior executives and board members are increasingly seeking to build integrated, risk-based and efficient AML compliance control programs, Financial services firms are well advised to ensure cultural changes towards compliance-driven objectives are made as a key priority if they wish to avoid their reputation being tarnished by potential scandals. Those who find themselves unexpectedly caught up in money laundering investigations whether as witnesses or suspects will need to seek the advice of those in the know to help implement detection and compliance initiatives.

Acquisition International looks into the key issues in AML policy and compliance with commentary from experts in field.

Benedict Wong is the President & CEO of Total Credit & Risk Management Group.

Benedict Wong founded Total Credit & Risk Management Group (“GCS Hong Kong”) jointly with Neil Wood (GCS Group Chairman) in 1987.

During the past 25 years of dedication to the credit, collection and risk management industry as a whole, he has contributed to various articles, industry newsletters and appeared in several television interviews for local and international media. He has also been a guest speaker at numerous conferences in Europe, Asia and USA, when he has spoken on topics concerning credit, collection and risk management.

Mr Wong is currently serving as GCS Group’s Regional Director – Asia; Chairman of ASIAGATE Group, since 2011; and fellow and Executive Committee of the Hong Kong Credit & Collection Management Association (HKCCMA).

Mr Wong formerly served as ACA International’s Director of International Unit (Asia-Pacific) 1999-2001, Chairman of International Unit (Asia Pacific) 2001-2003; and Chairman of Hong Kong Credit & Collection Management Association (HKCCMA) 2000-2010.

He is an active member of the World Investigators Network (WIN), World Association of Private Investigators (WAPI), National Association of Legal Investigators, Inc. (NALI) & World Association of Detectives, Inc. (WAD).

“Since 1987, we have been at the forefront of providing global credit and risk management services (including AML consulting) with a focus on Greater China (Hong Kong, China, Taiwan and Macau) and the Asia-Pacific region,” said Mr Wong.

Mr Wong explained that the main factors to consider when implementing and anti-money laundering system include the identification of risk-based suspicious activity monitoring scenarios, determination of current limits for scenarios identified and the implementation of a customised policy which needs to be integrated with the institution’s internal structure.

Discussing compliance programs, Mr Wong stated that the firm can ensure effective implementation of the Federal Financial Institutions Examination Council (FFIEC) BSA/AML manual, which have the Four Key Pillars of AML program clearly defined.

“One of the Four Key Pillars is the appointment of a BSA Compliance officer, who is responsible for managing communication with regulatory authorities for all AML-related issues and reporting, and has a direct line of communication into the board of Directors and Senior Management.” he explained.

When performing money laundering vulnerability assessments, compliance program evaluations and gap analyses, etc, the firm analysis the existing customer base and its transactions activities to enable effective limit-setting of particular scenarios.

“We perform in-depth analysis to identify current limits, based on customer segment and the risk level exhibited. We will develop a methodology that will allow institutions
to formally document these actions so that they can be shared with regulators to exhibit due diligence,” he concluded.