KNOW YOUR CHAPTER
ACAMS Germany Chapter : 2022 in review
In 2022 , the ACAMS Germany Chapter hosted four online and two live events on a range of topics , including regulatory developments and new approaches to mitigating financial crime more effectively using an intelligence-led approach . Given the major regulatory developments in the crypto space , our first two live events , which took place toward the end of the year in Frankfurt and Berlin , focused on the nexus of the crypto regulation to anti-financial crime ( AFC ), bearing in mind what can be expected when the European Union ’ s Anti-Money Laundering Package ( EU AML Package ) comes into force .
We also hosted an informal get-together in one of Berlin ’ s nicest outdoor summer bars ( Prater Biergarten ), with the international community of young and dynamic AFC professionals who have made Berlin their home as attendees .
The following summaries are the main details of the events and key points of discussion which came out of our knowledgesharing events .
• January — Regulatory transformation and regulatory strategies
The event discussed the state of play regarding the regulatory landscape of the European Union ( EU ), including the Transparency Register and Financial Information Act , as well as the upcoming Sixth EU Anti- Money Laundering Directive and the EU money laundering regulation . The focus of the event was customer verification obligations ( know your customer processes ) and the complexities attached , such as the trustworthiness of information and the beneficial owners 25 % threshold , which will apply at every shareholding level for both capital and voting shares . Previously , this threshold only applied to the first level of shareholding . Furthermore , experts discussed the role of the transparency register in light of the new regulations with a specific focus on register networking and digitalization . The discussion focused on what strategies can support obliged entities in achieving an optimal regulatory fit .
• February — Germany ’ s approach to PPP — How banks and law enforcement can cooperate to improve AFC efforts
Experts from the banking , nonfinancial sector and the public sector discussed how effectiveness in financial crime prevention can be increased through domestic and international public-private partnerships ( PPPs ) and the exchange of knowledge and information . The speakers presented the development of the Anti- Financial Crime Alliance in Germany and the transnational experiences within the Europol Financial Intelligence Public Private Partnership ( EFIPPP ). Besides explaining what PPP initiatives are currently up and running and what kinds of activities they are engaged in , the panelists discussed how PPPs could support in adding value to efforts aiming to curtail financial crime , in particular in the area of information sharing . Every year , banks spend billions of dollars on core financial crime compliance systems and are filing more suspicious activity reports ( SARs ) than ever . Despite these process improvements , the global antimoney laundering ( AML ) regime does not appear to be substantially more effective . Surveys of past and present heads of national financial intelligence units ( FIUs ) indicate that only a relatively small handful of SARs are of immediate value to law enforcement ( LE ), whereby acknowledging that any SAR that is not of immediate value could still become valuable in the future , given that investigations often develop over the course of many months and years . While some FIUs data mine all their SARs to uncover trends and typologies or to develop new insights into networks that are only made clear after the SAR is placed in context , many do not , thus highlighting the importance of ongoing exchange in the context of PPPs .
148 acamstoday . org