On September 19, 2023, the ACAMS New York Chapter held an in-person event titled Navigating Cross-Border Compliance: Understanding the Impact of Global Regulations on US Firms, which was sponsored by Moody's Analytics. The event was moderated by Nirvana Patel (Board Member, ACAMS NY Chapter) and included the following panelists: Jill DeWitt (Financial Crime Compliance Industry Practice Lead, Moody’s Analytics), Kemi MacGregor Dickson (US Lead for Regulatory & Policy Payments Compliance, Google), and Ken Triemstra (Head of Global KYC Policy, Standards, and Advisory, Citi).
The discussion began with a background on the risk-based approach championed by the Financial Action Task Force and recent updates to regulatory frameworks that appear to move certain jurisdictions away from the risk-based approach. The evening's discussion focused on managing AML compliance programs across diverging regulatory frameworks. Panelists discussed recent actions by the European Banking Authority, including its report on money laundering and terrorist financing risks associated with EU payment institutions. The EU's "single rulebook" to harmonize EU regulations is more prescriptive than the current risk-based approach, which can lead to financial institutions derisking. Diverging definitions across jurisdictions, such as what is considered a beneficial owner, are creating friction for financial institutions.
The conversation moved to nuanced requirements around the globe, such as countries with constantly changing regulations that are effective immediately, and how financial institutions can approach challenges. Financial institutions can be proactive by partnering with the public sector and responding to public consultations to influence and inform regulators of impacts. Dialogue with regulators is more impactful when the discussion focuses on impacts to consumers and derisking rather than costs.
The discussion concluded with the following takeaways: bring business partners into strategy because they can be powerful advocates, think globally wherever possible to find efficiencies and prevent building in silos, and use a common language and define common definitions to see what can be automated.