Matthias Verbeke - August 4, 2015
Open questions inviting a debate! Participate with us.
At a high level, AML IV will expand the scope of customers and entities subjected to due diligence, require firms to maintain flexible risk processes and demand reporting to beneficial ownership registries. How does this affect the Private Banking and Wealth Management industry?
How can smaller players, faced with high risk customers and transactions, ensure they harvest all the data about their customers available on the internet? Can this be done without infringing essential data privacy concerns? Will this require further investment in specialized staff? Will this generate more collaboration between private banks and wealth managers?
Flexible risk processes: will this require upgrading AML monitoring systems or replacing inflexible first generation? Will the industry revert to more external consulting to determine how and when risk models need to be adapted? How does the local regulator see this? Is this going to accelerate the cessation of the relationship with high risk customers or will this create new opportunities for institutions investing in more granular and precise AML risk management?
Should the industry wait for the creation of official UBO registers, or will the regulators insist on immediate action? Will self-declaration suffice or are further checks required? Are external list providers sufficiently secure, can we trust the accuracy and timeliness of the information they provide?
I suppose more questions will float around, we would be keen to start a debate around these topics.