Consulting Services for Management & Banking
Synergies Between
AML & Fraud
Departments/Programs
Presented by: Ana Maria H. de Alba
April 5
th, 2012
AML & Fraud
Policies & Programs
1.
Developing a Fraud Prevention Program makes it clear
that:
a)
Fraud by employees will not be tolerated and all
employees are responsible for its prevention
b)
Government & taxpayers take fraud very seriously
2.
Developing an AML Program makes it clear that:
a)
Money Laundering prevention is the responsibility of all
employees in an organization
b)
Government and the international community take
Definitions
What is fraud?
There are several types of fraud; one of its
principal definitions is:
concealment of material
facts
Fraud is generally divided into three major
categories, one of which is:
fraudulent
statements
What is Money Laundering?
The process by which the
origin or source of
funds
are
hidden or obscured
in order to make
that source appear legitimate
Both the AML and Fraud Prevention Programs
require, essentially, the same strategies:
Setting
Tone at the top
Implementation of
policies
Robust system of
internal controls
(include appropriate
technology, case management, and monitoring tools
;)
Ongoing
training
Periodic
testing or audits
of the effectiveness of the
implemented internal controls
Establishing a
Financial Integrity Unit and an AML
Compliance Unit
Note: An AML/CFT Program also requires the designation of a senior manager responsible for executing and
supervising the Program (The Compliance Officer)
Similarities in
o
Generally, an organization will be alerted of the
occurrence of fraud or possible money laundering
via:
Similarities in Detecting
Fraud & Money Laundering
Alerts
produced by the
internal
control system
(i.e. monitoring,
internal reporting mechanisms, etc.)
Internal or External Audit
(i.e. noted
discrepancies, transaction testing,
etc.)
Notification
from
Supervising
authority or law enforcement
For an entity to have an adequate prevention program, it
must:
Develop, document, and implement a
Policy
(
approved by your
entity’s BOD)
Conduct a
risk assessment
to identify vulnerabilities in each of
the major categories
Fraud:
Fraudulent Statement, Corruption, and asset
misappropriation
AML:
Customers, Products & Services, Geographies
Apply control procedures on the basis of
materiality and risk
,
and conduct due diligence on existing relationships (customers,
employees, and vendors) at appropriate times.
The Fraud & AML
For both the Fraud and AML Prevention Programs, entities
must also apply:
Appropriate Oversight (i.e. audit committee, AML
committee, AML Compliance Officer, internal audit team,
independent consultants, etc.)
Internal audit control
Separation of duties or division of responsibility
Ongoing training
Reporting mechanism (including anonymous suspicious
activity reporting)
The Fraud & AML
The Fraud & AML
Leverage/capitalize from internal information
Liaise with each Unit
Participate in Committees (i.e. Compliance
Committee, Audit Committee)
Negotiate on technology tools (i.e. case
management tools, monitoring, etc.)
Coordinate efforts for detecting suspicious activity
Credit card customer from Mexican institution:
Entity receives call from Hotel at time of customer
check out from a Starwood Hotel (Sheraton Hotel) in
Dallas, Texas:
Customer did not have sufficient credit in card
Customer claimed to have “deposited” $10K for the trip
on his card
Checkout balance was $13K +
Customer claimed that with his “deposit” and his line of
credit he should have had sufficient to cover
Credit Card division was quickly evaluating if a line
increase or temporary overage was possible
KYC profile disclosed that customer was a teacher in
Mexico
Case
Tone at the Top
Ana María H. de Alba, is an independent risk management consultant. She is the founder and Principal of Consulting Services for Management and Banking (CSMB), established in Miami, Florida since 1997. She is also an associate at various internationally recognized business intelligence, investigations, and security firms, and is the FIBA AML Institute’s lead instructor .
Ana Maria has over 24 years experience and training in both the banking and consulting industries. As a banking executive, she worked in domestic and international financial institutions, including Sun Trust, Banco Atlántico, International Finance Bank and Banco Internacional de Costa Rica. As a consultant, she has spearheaded and participated in numerous risk management and investigation assignments and projects in the USA, Venezuela, Brazil, Chile, Ecuador, Uruguay, Colombia, Mexico, Peru, Panamá, Honduras, Costa Rica, Guatemala, and the Caribbean.
Her professional history and accomplishments include supervision and development of risk management and assessment projects, as well as numerous other projects in forensic investigations linked to money laundering and financial fraud. Additionally, she has been engaged in projects concerning currency exchange; strategic organizational planning; investment analysis; market analysis; development of banking products and services; development and implementation of policies and procedures for all units within a banking institution; training and development, including public speaking on AML subject matter; development of compliance programs; and “look-back” or forensic review projects.
Ana Maria de Alba has an undergraduate degree in Business Administration with a Major in Finance from the University of Miami, as well as an MBA with emphasis in Banking and Finance from Nova Southeastern University. Additionally, in AML subject matter, Ms. De Alba is certified by FATF in “Methodology for Mutual Evaluations” as an expert country evaluator and is certified in Anti Money Laundering by FIBA in association with FIU, with both the AMLCA and CPAML designations.
