Reducing financial crime is a key priority for regulators, authorities and governments globally.
Organised crime groups, terrorists and fraudsters are increasingly using sophisticated international networks and financial systems to move or store funds and assets or commit fraud.
Financial institutions are particularly vulnerable due to the nature of their businesses and the volume of transactions and client relationships they manage. Global financial institutions also face multiple legal and regulatory requirements in Luxembourg and other countries where they do business.
Recently we have witnessed an increased willingness of regulators to pursue individual firms and impose tougher penalties for breaches of regulations, particularly in the area of money laundering and corruption where some unprecedented fines have been levied. US prosecutors have also levied large fines against non-US financial institutions for breaches of economic sanctions.
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Deloitte provides clients with a range of specialist services to help them navigate this complex, high-stakes environment:
Money launderers devise evermore creative ways to use legitimate business to launder the proceeds of crime. The fight against money laundering and terrorist financing is at the top of governments’ and regulators’ agendas. Concrete consequences of those changes include the AML law last updated in October 2010, the enlargement of primary offences and the new 40 FATF recommendations released in February 2012.
The Office of Foreign Assets Control (OFAC) has launched investigations into several financial institutions over the past few years for alleged breaches of OFAC rules concerning embargoes and financial transactions with restricted entities. US prosecutors have levied large fines against non-US financial institutions for breaches of economic sanctions.
It is no longer adequate for firms to simply deal with fraud as it arises. It is necessary to have an effective fraud risk management strategy in place and to be able to demonstrate that you are engaged in financial crime risk management.
Preparing for the Foreign Accounts Tax Compliance Act (FATCA) in June 2013 requires the identification of US persons in financial institutions’ clientele. Some account holders may not have disclosed the necessary information or financial institutions may not have recorded it in electronic format which adds complexity to the verification and due diligence exercise.
Disputes and litigation tend to flourish in times of crisis and upheaval. A clear understanding of disputed events is essential to define a course of action in case of conflict. We act as independent expert to the Court in the context of litigation and dispute resolution.