During our regular ‘Ask Me Anything’ sessions, the entire Napier team is honoured to spend a virtual hour with a heavyweight in the world of AML, compliance or enforcement.
These sessions are a fabulous learning opportunity. They provide us with highly personal experiences and insights into life on the front line of fighting financial crime. While much of what we talk about is sensitive, we’ve also been able to share many highlights over the last few months.
During August, we had the pleasure of speaking to Jessica Chuah, Director of Compliance at Clik. Clik is a Napier client and a unified digital payment ecosystem that’s improving financial inclusion in Cambodia. Jessica kindly shared her vast experience with us and here we delve into some of the key points she made:
1. The repercussions of non-compliance should be feared
As a compliance specialist in Cambodia, Jessica knows what it’s like to have the weight of compliance on her shoulders. From mitigating the risks of operating within a high risk jurisdiction, to worrisome sleepless nights, Jessica hit home the reality of AML compliance when she explained how she chose Napier to not only ensure Clik is compliant but ultimately, that her boss doesn’t go to jail.
For Jessica, choosing the best compliance technology available is the only way to have peace of mind and confidence when speaking with regulators.
2. Compliance is not a check-box exercise
Compliance is about personal professional conduct and integrity. If strive to comply to the highest possible standards rather than the bare minimum, you will know you are operating in the best possible way to mitigate the risk of money laundering. Compliance is not a superficial check-box exercise – it involves deeply rooted processes supported by great people, policies, data and technology.
3. It’s essential to be able to change the rules when operating a risk-based approach
Using rules as part of a risk-based approach to transaction monitoring is extremely common. Rules are clear and easy to understand and audit. However, Jessica highlighted how inappropriate it is to operate a risk-based approach with pre-set rules:
“Changing the rules shouldn’t be a difficult experience but very often software vendors supply rule-based transaction monitoring systems with a set of pre-configured, restrictive rules.”
Jessica highlighted that what differentiates vendors is whether you are able to independently create, test and change rules within your user interface, as is the case with what she describes as Napier’s “rules toolkit experience”.
When using a traditional AML solution, it is a normal to have to go to the vendor to request new code to be written every time you want to add or change a rule. But this is expensive, difficult and time consuming.
Moreover, Jessica describes how “you have to be able to respond quickly to regulatory changes. You need to have the autonomy – it’s no good feeling handcuffed, like you can’t move. You need to have the decentralised model to be able to design the whole AML/CTF programme. If you have to ask a third company for rules to be changed, this inevitably causes delays and hinders you in doing your job.”
4. Work with your regulator for success
While some regulated entities may fear the regulator, Jessica works closely with the Cambodian Financial Intelligence Unit (CAFIU) to ensure Clik’s compliance. Jessica stresses how she has learnt how important it is to regulators to have accurate information in a timely manner, including the massive ask of 24-hour STRs. Ultimately, Jessica knows if she fails to provide the CAFIU with the information they need, they will come back and look to investigate system deficiencies. This is why choosing a superior AML system is the best way forward for both peace of mind and compliance.
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