• Emerging Technologies

    Emerging technologies are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Emerging Technologies

What are the ML/TF Risks?

Emerging technologies are technical innovations which represent progressive developments usually resulting for competitive advantage over existing products or business methods.

Financial technology, also known as FinTech, is an economic industry composed of companies that use technology to make financial services more efficient.

Financial technology companies are generally start-ups founded with the purpose of disrupting incumbent financial systems and corporations that rely less on software.

The Money Laundering and Terrorism Financing (ML/TF) risks associated with emerging technologies include:

  • Potential anonymity characterised by non-face-to-face customer relationships;
  • Record keeping standards that do not capture relevant data such as IP addresses can disguise audit trails and hamper law enforcement efforts;
  • Anonymous funding of products may result in no or insufficient paper trails regarding the funding transaction and the origin of the funds;
  • Ability to offer products in multiple jurisdictions and effect cross-border transactions; and
  • Multiple parties can be involved in performing the payment service jointly, such as card issuers, program managers, exchangers, distributors and other types of intermediaries or agents.

Emerging technologies must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for businesses offering emerging technologies in the financial sector.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

Who has used AML Accelerate in this sector?


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