探索欧洲反金融犯罪的下一个时代

© Oliver WymanEXECUTIVE SUMMARYAs European Anti-Financial Crime (AFC) executives are looking ahead to the challenges of2025, they must address a number of key priorities to continue developing and enhancingtheir AFC risk managementframework.2024 saw significant regulatory enforcement activity, primarily stemming from failures inanti-money laundering, sanctions violations, and compliance lapses. These developmentsserve as a stark reminder of the critical need to maintain the effectiveness of AFCorganizations while contributing to cost rationalization initiatives that many institutions arecurrentlyundertaking.In this complex landscape, AFC executives are tasked with navigating a delicate balancebetween effectiveness and efficiency within their organizations, all while staying informedabout evolving regulatory requirements and the shifting expectations of geopolitics andsociety regarding the efforts and outcomes of financial crimeprevention.Through our conversations with AFC executives in the second half of 2024, we haveidentified four recurrent key themes. These themes encapsulate the critical areas of focusnecessary for strengthening and transforming their AFC systems and controls to adapt tothe evolving landscape of financialcrime.AFC executives will need to have an answer and strategic plan for each theme to steerthrough 2025 and beyond. © Oliver WymanSTRENGTHEN AFC PROCESSES, TECHNOLOGY ANDWORKFORCE FOR GEOPOLITICAL RISK RESILIENCEThe current geopolitical landscape is marked by significant uncertainty, presentingchallenges for AFC organizations. As geopolitical tensions rise due to current developmentsin Syria, the Middle East, Taiwan, and Ukraine, the complexity of compliance requirementsintensifies, driven by rapidly evolving regulations and an expanding array of internationalsanctions programs. Financial institutions find themselves navigating a labyrinth ofcompliance obligations that are not only intricate but also subject to frequent changes.The geopolitical dynamics, combined with the necessity for consensus within the EU toimplement sanctions, are further complicated by elections and social unrest in EU memberstates. This confluence of factors leads to a significant divergence from a unified EU stanceon the formulation of additional sanctions packages. This situation is further complicated bythe widely anticipated shifts in the traditional US coalition, as the new Trump administrationis set to take office in January 2025. These changes could significantly influence theeffectiveness and coordination of sanctions on a global scale. As a result, institutionsmust swiftly adapt their control frameworks to be prepared for upcoming changes. Thepace of regulatory change often outstrips the capacity and capabilities of institutions toeffectively implement necessary adjustments, leading to breaches, backlogs, and potentialvulnerabilities in their complianceefforts.As AFC organizations strive to maintain compliance in this volatile environment, they mustenhance their monitoring and response mechanisms to mitigate risks and safeguard againstpotential breaches. This requires a comprehensive understanding of the geopolitical contextand its impact on financial crime risk management. AFC must maintain a close partnershipwith the business to ensure a comprehensive understanding of risk and to sustain aneffective control framework. This collaboration is essential for aligning anti-financial crimeefforts with business objectives and enhancing overall riskmanagement.AFC executives should:1.Assess the agility of process management and control functions, to expedite thereengineering of relevant operating model processes and controls whereneeded2.When transforming the control framework, AFC executives must closely monitor itsoperational effectiveness. Senior management should receive comprehensive andrelevant information to provide assurance that the program is robust and functioningas intended3.Assess the current AFC technology and data architecture, and ensure it is sufficientlyflexible to absorb new detection methods to more effectively identify potentialriskexposure4.Assess and enhance AFC risk culture to foster an environment where AFC complianceand risk management are prioritized, encourage open dialogue about risks, and promoteaccountability at alllevels © Oliver WymanPREPARE FOR A NEW ERA OF FINANCIAL CRIME REGULATIONWITH THE ANTI-MONEY LAUNDERING AUTHORITYThe establishment of the Anti-Money Laundering Authority (AMLA) represents asignificant shift in the regulatory landscape across Europe. The AMLA is expected toenhance the consistency and effectiveness of AML/CFT practices among member states,providing a common framework for combating financial crime. While AMLA is an EUinitiative, its implications for branches and subsidiaries in third countries should notbeunderestimated.Institutions face a critical challenge to prepare for anticipated changes in regulatory practices,particularly considering the new require