Investment managers have to keep up with the constantly evolving nature of money laundering tactics and increasing sophistication of money launderers across global jurisdictions. New policies are continually being put in place to ensure that money launderers face a hostile environment. This is only set to continue as updates on AML evolve to keep up with the changing nature of financial fraud.
The European Union has increased its focus on AML in recent years, evidenced by the adoption of several AML Directives which have established a harmonised set of framework and set of rules. Recently, the EU has also adopted an AML Action Plan, outlining its intentions to further streamline AML harmonisation across the EU.
The complex global compliance landscape is further compounded by varying interpretations of rules and standards at an institutional level and differing approaches in designing and executing CDD programmes to fulfil regulatory expectations.
In order to get involved with AIMA work in this space, or to become a member of our dedicated AML Working Group, please contact Remmert Keijzer.
AIMA White Paper
AIMA has published a White Paper on Improving AML/KYC/CTF Due Diligence Processes: Centralisation and the Benefits of a Digital Solution. In the White Paper, we are offering a range of targeted options that could be implemented that would improve the customer due diligence process and would create scenarios in which compliance with AML, CTF and KYC requirements are safeguarded, while strengthening the role of regulators as standard setters.
- Inefficiencies around CDD are placing a significant cost and administrative burden on financial services firms and investors
- The challenges faced by all parties involved in the CDD chain complicate global harmonisation efforts
- Regulated entities should be able to perform CDD for others on a reliance basis for multiple jurisdictions which would streamline CDD practices while safeguarding international standards
- Podcast on AML: ACA Compliance Group - AML outsourcing factors and challenges (26 November 2020)
- Podcast on AML: Simmons & Simmons, Ireland - CBI guidance on 'transactions' (28 February 2020)
AIMA responses & other documents
- AIMA responds to FinCEN on proposed beneficial ownership disclosure programme (04 May 2021)
- AIMA Submits Response to SFC on Revised AML/CFT Guidelines (24 December 2020)
- AIMA White Paper on Improving Customer Due Diligence Processes (20 October 2020)
- AIMA responds to HM Treasury's Economic Crime Levy (08 October 2020)
- AIMA responds to Dutch consultation on UBO register for non-corporate entities (19 May 2020)
- AIMA’s response to the BEIS’ corporate transparency and register reform consultation (31 July 2019)
- Proposed Notice on Prevention of Money Laundering and Countering the Financing of Terrorism for VCCs - AIMA Submission - MAS (30 May 2019)
- Letter to John Glen MP regarding public registers (02 May 2018)
- Letter to BEIS to follow up on the Register of People with Significant Control regulations (09 October 2017)
- Proposed Legislation to create central beneficial ownership platform - Cayman Islands Government (12 December 2016)
- AIMA response to the BIS discussion paper 'Understanding the new requirements, recording control on the PSC register and protecting people' (09 December 2014)
- Small Business Enterprise and Employment Bill - Position Paper (05 November 2014)