AML Compliance challenges when operating in a multi-jurisdictional environment

Affinity Group is a multi-jurisdictional Corporate Service Provider with offices in the Isle of Man, Malta, Cayman Islands, and Florida in the USA. They serve customers in various sectors including yachting, aviation, fintech, eGaming and private wealth.

Recently, Affinity Group became an InScope-AML customer and we reached out to Rachael McGeachie, Director and Head of Group Compliance who is based in Douglas in the Isle of Man. Rachael gave us some insight into the company’s experience in AML compliance and their use of InScope-AML.

As a person with extensive experience in AML compliance, how have you seen this sector evolve over the past few years?

Whilst the legal and regulatory landscape is ever-evolving, the rate of that evolution has increased in recent years owing to many factors. At the heart of AML compliance is the need to be agile and proactive to the growing sophistication of the risks posed by bad actors whose aim is to abuse the financial system. Advancements in technology, geopolitical factors leading to what could be described as a sanctions emergency across industry, and the fallout from the global pandemic have all added to the challenges faced by those of us within the compliance community.

These evolving risks meant that traditional compliance monitoring programs needed to improve to remain fit for purpose.

What challenges are associated with operating in a multi-jurisdictional environment?

Although global standards are set in terms of AML/CFT/CPF, there are jurisdictional specifics that vary between operational locations. Whether that is the regulatory environment that we as trust and corporate service providers work within or the framework adopted by industry partners we engage with for complimentary services to our clients such as banking.

Nuances in basic verification of identity to more complex differences in establishing the source of wealth can make operating across multiple jurisdictions a balancing act.

As Head of Group Compliance, which specific challenges in managing AML compliance prompted you to seek a solution?

Deploying a group-wide compliance and risk management framework that caters to our individual regulatory requirements in each location requires careful and well-thought-out controls. Affinity has always adopted a robust approach to compliance processes that has developed in line with our business and client base. To ensure this approach remained consistent and in line with our business needs, I sought out options for a solution that could be adapted to our specific needs and would bring efficiencies and safeguards to managing our client base.

What features or benefits led you to choose InScope-AML as your preferred option over other solutions you considered?

InScope-AML was the obvious choice for Affinity. We were able to build bespoke controls around Affinity’s requirements. Born out of our compliance culture, our specific risk management controls and requirements were used to design the core factors of the InScope-AML system we use today. I was able to translate our detailed client risk assessment parameters into what the system would apply to our clients, their structures and activities.

InScope-AML didn’t present as a “tick box” option as other solutions do. It provided a meaningful tool to manage the ongoing risk assessment of our client base whilst offering the flexibility to change in line with our ongoing business risk assessment and business needs.

Which features of InScope-AML have had the most significant impact on your work?

The automation of our customer risk assessment process, tracking their completion, having prompts to revisit at periodic intervals as well as trigger events when jurisdictional changes occur.

Having ongoing screening of the client base in the same place as our CRA system so we could be confident that all necessary screening was being done on a consistent basis.

The reporting function has greatly assisted in management reporting, regulatory reporting and overall risk assessment for the group.

Being able to undertake a customer risk assessment during new client onboarding and revisiting this throughout the onboarding process has greatly assisted in documenting that process in a more meaningful way than when this was a manual process.

Can you provide examples of specific compliance issues that InScope-AML has helped resolve?

As above in features, having automation of risk assessments falling due for periodic ongoing monitoring as well as at trigger events owing to screening results and/or changes to country risks.

Are there any quantifiable cost savings or ROI that your organisation has experienced since implementing InScope-AML?

InScope-AML has saved on average three full days of my time per month and when a trigger event occurs, such as a jurisdiction being subject to FATF warnings / grey listing, any exposure across the entire client base is automatic and therefore saves many hours of manual review.

How would you describe the support provided by the InScope-AML team throughout the process?

The support provided by the InScope-AML team has been outstanding. The team has been on hand to guide me throughout the set-up process and proactive to our specific requirements. It has felt like a very personal approach and they have always been on hand to help.

Would you recommend InScope-AML to other compliance professionals? If so, why?

Absolutely! InScope-AML is cost-effective and user-friendly. The system is designed to complement our AML/CFT/CPF requirements and can be bespoke to individual business needs. All members of the team are knowledgeable and passionate about their product.