Important insight for the financial institutions from Laura Aus, Deputy of Estonian FIU: "Sanctions screening is not enough to mitigate the risk. Smart solutions for risk indications must be put into use"
What are your thoughts of how to achieve that? And what kind of smart solutions can be used?
During my audits I often see that only sanction screenings are made, but no deeper diggings performed.
In general, from my point of view, the steps are the following for better risk management:
1. Understand the Sanctions related regulatory requirements and environment.
2. Identify and describe topologies and scenarios.
3. Conduct analysis of how your company, services, systems can be used for executing described scenarios.
4. identify vulnerabilities and threats in your processes and systems.
5. Assess your internal controls. (NB! pay attention to both - preventive and detective controls)
6. Compare your residual risk against the risk appetite.
7. Find solutions for improvement.
8. Continuously Monitor and of course involve internal audit :)
We were happy to share our views on sanctions performance at ACAMS Baltics Symposium. Deputy of Estonian Financial Intelligence Unit (FIU) Laura A.:
💡 Know your customer – the KYC principle – is just as important tool in sanctions application as it is for anti-money laundering
💡 Sanctions screening is not enough to mitigate the risk. Smart solutions for risk indications must be put into use
💡 Typologies for sanctions evasion are not new, but have become more complex in time
Together with other panelists Kane Baguley, Paulis Iljenkovs and John Smith we see a strong will to apply sanctions by both private sector and regulators!
#sanctions #lawfulassets #cooperation
interested in SAP, GRC, fraud management, internal controls, compliance, sanctions
7moThis is great! Congrats!