Anti-money laundering (AML) enforcement continues to be a focus for regulators around the world. While the bulk of enforcement action relates to financial institutions, fintech are finding themselves increasingly subject to scrutiny by regulators and the media. FRA’s Claire Wynne-Jones joins Jonah Anderson and Lucy Rogers of White & Case to outline how a fintech company might investigation AML enquiries as they arise, and also take steps to minimize risk exposure in areas that pose particular challenges to fintech.
Drawing on their experience with AML investigations and advisory work, the authors cover:
- Identifying employees and other individuals with relevant knowledge of the business, its operations and corporate history
- Considering all of the available data that may assist in the investigation (payment flows, payment infrastructure, KYC records and more)
- Performing forensic analysis on the data and other documentary evidence to identify patterns of suspicious activity
- Taking remedial action after an investigation, filling gaps in policies and procedures
