Dr. Tom O’Kane

An Enterprise Ireland

& IDA Ireland Initiative

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Funded by:

A Global Perspective

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• M • Money laundering costs

3-5% of global GDP ($1.5

– $3.5 trillion) per annum

• Banks spending >$10bn

per annum on AML

efforts

• Spending on AML has

risen 53% between 2011

& 2014

“The (US) Justice Department is now more

broadly examining whether a financial

institution’s AML processes are up to snuff.” Forbes (2012)

Organisations are now being penalised for the

inability of their processes to prevent money

laundering or sanctions breaches.

Reason: Failure to have an adequate

sanctions screening process in place.

Note: No actual breach took place

A compliance framework that:

1. Enables objective assessment of AML

capability

2. Provides a customised roadmap to

improve AML capability

The Regulatory Compliance Maturity Model (RMM) for AML

that we propose meets these requirements

Processes are proactive –

likely to give excellent

regulatory reviews

Processes are organization-

wide – likely to give good

regulatory reviews

Processes are consistent –

likely to give reasonable

regulatory reviews

Processes are basic – likely

to give mixed regulatory

reviews

Processes are poor or ad-

hoc – likely to give poor

regulatory reviews

Continuous

Incremental

Improvement

Capability Level 1

Capability Level 2

Capability Level 3

Capability Level 4

Capability Level 5

• The RMM is a process

technology and prime

enabler for identifying

people, process &

technology improvement

opportunities

• 5 enterprise-wide

domains contain 16 Key

AML process areas

• Leverages CMMI*, a

proven world-wide

standard for business

process improvement

*Capability Maturity Model Integrated, Software Engineering Institute, Carnegie Mellon University, Pittsburgh

• Focus on what’s

important

• Understand the

current capability to

effectively manage

AML

• Identify improvement

opportunities

Capability Appraisals using the RMM produce detailed findings and a

Maturity Profile that enables an organization to:

Training

Analytics

Data Mining

Process Automation

Process Re-Design

Outsourcing

Banking Services

Software Tools