Recognise that IWT is an issue that impacts all financial institutions, large or small. Firms should put in place a strategy, policies and procedures to address IWT to avoid ad hoc responses to this crime.
Make sure that clear roles and responsibilities for tackling IWT are known
and understood across all levels and departments within the business;
Recognise that IWT is a predicate crime for money laundering and embedded in existing AML/CTF (Counter Terrorist Financiing) frameworks
Identify the specific IWT related risks associated with their unique
business. Firms should use this to inform their non-lWT specific risk
indicators, such as via policies, procedures, systems and tools that help
them detect any potential linkages to IWT;
IWT typically converges with other forms of serious and organised crime
including trade-based money laundering (TBML) and corruption red flags.
These links are set out in more detail in the Toolkit. It is good practice for
staff to be aware of these links and to understand that existing
transaction monitoring systems looking at TBML and corruption may also
flag suspected instances of IWT.
A strong and consistent tone from the top will re-enforce IWT as a
management priority. We recommend that organisations designate one
board member or senior executive to have the overall responsibility for
championing the firm's response to IWT across the business.
The 'model' framework provided below is based on best practice and provides practical steps that Fis can follow to help them implement an effective set of controls against all forms of IWT. Firms may employ all or some of these components depending on the size and nature of their business as well as the level of existing controls they may have or not have in place.
Do you understand the specific threats or potential linkages to lWT your organisation is exposed to?
Are you confident you would be able to spot potential links to IWT?
Are you confident your team would know what to do if a potential suspiicion was raised?
Providing law enforcement with valuable information regarding IWT
Ongoing monitoring and management of your business to spot any future links or trends
Risk Assessment & Strategy
Risk Appetite
Horizon Scanning
Training
Policies
Systems & Tools
Proceedures
SARs
Annual MLRO Report
Key Risk Indicators
Management Information
Quality Assurance
Compliance Monitoring
Governance
