Intensive programme to tackle anti-money laundering issues

As part of the Maltese authorities' continued efforts to provide market participants in Malta with the ongoing education and training necessary to build effective anti-money laundering systems, a unique training programme on anti-money laundering is being held from May 8 to 12.

This programme gives participants the opportunity to hear from industry practitioners in Malta, the United Kingdom and the United States on how they approach this highly important issue.

The panellists include: Neil Munro, vice-president, AML - Morgan Stanley, London; Alma Angotti, attorney, NASD Enforcement and NASD Expert for AML; Karen O'Toole, vice-president and associate general counsel, Fidelity Investments; Dr Robert Clark, CFA, dean, University of Evansville Business School; FBI Special Agent Gregory Coleman; Gary Tidwell, vice-president, NASD - International Education and Training; and Allison Reid, director, NASD International Education and Training.

The speakers will be joined on the first day by Attorney General Dr Silvio Camilleri, who also chairs the Financial Intelligence and Analysis Unit, and Dr Anton Bartolo, registrar of Companies and director Corporate Services,

The topics to be covered include:

¤ the Third EU Directive on Anti-Money Laundering;

¤ anti-money laundering compliance programme requirements;

¤ developing and implementing effective identification programmes;

¤ suspicious activity;

¤ developing and implementing effective reporting policies and procedures; and

¤ global compliance issues.

Money laundering is a process through which the proceeds of criminal activities are converted into apparently legitimate assets with the objective of ensuring that those proceeds cannot be traced back to the underlying crimes and the perpetrating criminals.

The underlying criminal activities producing the proceeds to be laundered are diverse. These include bribery, extortion, trafficking in illicit drugs, theft and fraudulent schemes. However, regardless of the origin, the goal of money laundering remains the same - to conceal the proceeds of criminal activity effectively.

Why is it a problem?

Money laundering is considered a subversive influence on the integrity of the financial system because it corrupts legitimate financial and banking relationships by converting them into protective coverings for the movement of criminal proceeds and the financing of crime and terrorism.(1)

In so doing, it undermines the integrity of financial institutions as well as the global financial and trading systems that are key foundations of economic growth, development and prosperity.(2)

Efforts to tackle the problem

Within the past 30 years or so, there has been an increased focus on money laundering and its impact on national and international economies. The major pieces of legislation in this area have included The Vienna Convention and the First, Second and Third European Directives on Anti-Money Laundering.

In Malta, the anti-money laundering regime includes two important pieces of legislation derived from the European Directives: The Prevention of Money Laundering Act and the Preventing of Money Laundering Legislation.

Both are representative of Malta's strong commitment to build a robust framework to detect and prevent attempts to use various aspects of the economy to facilitate money laundering. Across all sectors of the economy, market participants are subject to increased responsibilities to take appropriate steps to detect and prevent money laundering.

Challenges

Market participants face a number of challenges in their efforts to create effective anti-money laundering systems. These stem from a number of factors, including the creativity of money launderers, the complexity of their schemes, the volume of information to be mined for suspicious activities, and identifying suspicious activities.

Importantly, anti-money laundering efforts need to occur at every stage of a client relationship. Further complicating this landscape is the coming of new legislation, which will implement the Third European Directive on Anti-Money Laundering.

This unique, interactive programme, is being organised by the MFSA, the FIAU and the LGA, and is intended to give delegates the opportunity to hear how others approach the day-to-day challenges of creating and maintaining an effective anti-money laundering programme, suggested best practices, as well as lessons learned from various cases.

The financial services content in this programme has been designed and will be presented in collaboration with NSAD, the leading private sector provider of financial regulatory services in the US.

The programme is recommended for staff at all levels, who have anti-money laundering responsibilities.

References

1. Peter Reuter and Edwin M. Truman, Institute for International Economics, Chasing Dirty Money: The Fight Against Money Laundering, at 130 (November 2004).

2. Ibid.