The professionals in the anti-money laundering (“AML”) services practice at Deloitte have assisted clients with AML issues for more than 20 years. Through our investigation experience, we have gained a deep understanding of the myriad of ways money launderers work — concealment of source/beneficiary, the use of shell companies and trusts, smuggling, counterfeiting, corruption, third-party fraud or theft/ diversion by insiders, etc. — and we have the skills and experience to help clients implement detection and compliance programs to counter these fraudulent activities.
Working with the DTTL worldwide network of member firms, we have designed, reviewed, enhanced, implemented and monitored numerous AML detection and compliance programs for clients around the world.
Our work has included assessing AML risk at the enterprise and business unit level, drafting and enhancing policies and procedures, creating and delivering training modules, compliance assessments, forensic “look backs” pursuant to regulatory orders, internal controls assessments, selection and implementation of technology solutions and internal investigations.
Anti-Money Laundering Consulting services include:
• AML gap analysis & compliance program assessments
• AML due diligence & know your customer assessments
• AML risk and control services
• AML technology consulting
• AML training
• AML transaction analysis (look back)
Our anti-corruption consulting practice helps organisations navigate risks and respond to potential violations in relation to anti-corruption legislation, such as the Foreign Corrupt Practices Act (FCPA). Utilising the network of Deloitte’s member firms and their affiliates including forensic resources in the United States, Canada, Europe, Africa, Latin America and Asia, we have worked on a variety of anti-corruption engagements including investigations, acquisition due diligence and compliance program implementation and assessments in over fifty countries for some of the world’s leading companies. We collect and analyse accounting data and other hard copy and electronic documents, including e-mail, to identify the ‘red flags’ of potential violations and gaps in companies’ anti-corruption controls.
Anti-Corruption Consulting services include:
• Anti-corruption investigations and look backs
• Anti-corruption due diligence
• Anti-corruption programs and controls
Economic and trade sanctions are imposed by governments or multi-national organizations such as the EU or UN to further foreign policy objectives; for example to address state to state security threats or human rights abuses. Sanctions generally prohibit companies and individuals from entering into or facilitating transactions involving sanctioned regimes or designated entities or individuals in order to limit their access to capital markets and goods.
The challenges and risks posed by economic and trade sanctions should not be underestimated. Establishing which sanctions regime applies, and under which circumstances, is by no means straightforward. Organizations face tough decisions when striking the right balance between having a conservative enterprise-wide sanctions policy and an efficient real-time transaction screening approach that does not adversely impact its ability to execute transactions competitively. Recent enforcement actions between global financial institutions and their regulators and law enforcement have demonstrated the significant potential costs, both tangible and intangible, of failure to comply with economic sanctions requirements. Most notably, to settle United States investigations after admitting violations of United States sanctions, several financial institutions have paid up to hundreds of millions in fines.
Deloitte has experience in providing overall, discrete, and timely advice on sanctions programs risk management and compliance. We have worked with many of the world’s largest financial services institutions and have well-established relations with the relevant regulators. With a global practice and centres of excellence, Deloitte is well positioned to assist entities including financial institutions, insurance companies, asset managers and investment funds in meeting the challenges posed by sanctions regimes around the world.
Growing focus on corrupt activities
By Chris Rowland