The Vital Importance of AML and how UBP is Fighting Financial Crime
Swiss private bank Union Bancaire Privée (UBP) in Singapore has teamed up with Singapore Consultancy and Hubbis to roll out a market-leading training programme on Anti-Money Laundering (AML). The three partners consider this to be a vital subject in which to train professionals in the wealth industry, knowing that private banks are now effectively on the front line in preventing such illicit funds from infiltrating the financial system.
Private banks are now effectively on the “front line” in preventing illegitimate funds from entering and then circulating around the financial system. A long-term, sustainable business depends on a solid and effective AML framework. Some of the key elements include governance where a culture of vigilance must be strong, risk awareness and personal accountability, and rigorous execution with the right systems and technology.
Governance centres on the need to build and retain a robust internal compliance culture. Risk Awareness focuses on the collective and individual accountability at each bank and institution. And the third pillar - Execution – involves the adoption of sound and workable policies that will serve as a sturdy barrier to prevent a bank from being exploited for criminal money laundering purposes.
Boosting professional expertise
The Anti-Money Laundering (AML) Training programme, therefore, has a critical role to play in boosting the professional expertise, the understanding and the culture to ensure that any private bank, such as UBP, steers well clear of any such risks.
This is also especially timely because the regulators in this region, whether the MAS, HKMA or others, expect all banks to have robust compliance regimes in place that can adapt quickly to the rapidly evolving and immensely complex modes of AML attack and the broader risks associated with financial crimes.
As Ranjit Khanna, Head of South Asia and Singapore Branch Chief Executive at Union Bancaire Privée (UBP) explains: “The wealth management industry in Singapore has come a long way in raising AML standards and awareness. But collectively as an industry, we must recognise that this is a journey and not a one-off destination. We have to keep learning, adapting and constantly improving our processes in order to play our part in the battle against money laundering.”
Indeed, UBP understands that building and refining the knowledge needed to combat money laundering is not only a vital task, but also an existential imperative. Working with training providers Hubbis and Singapore Consultancy, UBP is committed to creating and pursuing the best and most innovative ways to make its new Advanced AML Certification training programme both relevant and useful.
A key element in shaping the learning experience at UBP was the recognition of a need to move beyond what might be termed ‘off-the-shelf’ or generic type content. To make the details understandable and the key messages of the training programme endure, participants need to feel engaged in the reality of what money laundering can look like in real-world situations.
They also need to be fully aware of the reputational damage that can be inflicted – short and longer-term – to names and brands built up and carefully nurtured over many decades. Everyone involved in private banking has this collective responsibility; this is not a matter to be taken lightly or simply to be shut away in some compliance cupboard.
Khairul Alam, Head of Compliance Asia at UBP stresses this point: “Understanding and then applying our AML procedures has to become instinctive in all of our interactions with clients. All staff have a responsibility to protect the bank and our broader communities against the risks posed by money laundering and terrorist financing. Our AML training and certification initiative is not a one-off; it is a lasting and constant commitment. We will continue to refresh it on an ongoing basis to benefit the front line.”
Arming and targeting
The programme launched in July 2021 and set out to deliver AML training recognised and accredited by the Institute of Banking and Finance (IBF) under the Financial Training Scheme (FTS).
UBP was determined to make sure that Singapore relationship managers and customer relationship assistants would have the tools and the confidence needed to be able to react correctly in the client-facing live environment. This involved actively reimagining the ways in which AML knowledge could be communicated and delivered. And the ultimate objective, of course, is to prevent the bank from becoming an unwitting participant in any form of pernicious money laundering.
Re-engineering for future challenges
The project lead at Singapore Consultancy is Stefan Kuhn, and he was clear about doing things differently to bring freshness and energy to the training. He has stated: "We tried to re-engineer everything from scratch to turn training designed for Compliance Officers into a meaningful one to address the day-to-day challenges of the front-line staff in the best way possible. That's why we included workshops, role play and interactive elements - to make the training matter."
The collaboration with Singapore Consultancy and Hubbis resulted in a one-day training session divided into two elements. The first covered essential details of how money laundering has changed and how to combat it in the actual world of client interaction.
The second part of the training day was interactive and in a workshop format, with lively discussions and case studies based on the realities of how criminals attempt to ‘clean’ money or other assets in the financial network. Participants were able to share best practice ideas about how to respond and each case study involved coming up with “what would I do, if…” type answers. The session concluded with a thorough online assessment which RMs and CRAs have to pass to complete their training and obtain accreditation.
Thinking outside the box
Michael Stanhope, Founder & CEO at Hubbis, is pleased with how the training programme and methodology worked out for all involved: “This project was a new and exciting departure from our standard online learning – which UBP has utilised for nearly ten years. The task was to maximise the value for those having to face up to and make decisions around AML, often on a daily basis. What I saw when shadowing one of the full-day sessions was that the training provided critical skills for those working at UBP to apply their knowledge and insights with full confidence.”
The AML training programme is timely as those individuals and entities who make crime their business have become more sophisticated and tax-related crimes are increasingly a focus for regulators worldwide. Gone really are the days of cash stashed in suitcases; today, the methods used are far more sophisticated as criminals of all types seek to hide and launder the proceeds of their illegal activities. Cryptocurrencies present a further widening of the AML risk universe and an additional challenge for all concerned.
Meeting the challenges head-on
The wealth management industry in Asia has had to step up to deal with the threat. Meeting the highest standards of AML compliance required by the regulators will help to protect the banks. And inculcating the right internal culture of collective awareness, alertness and diligence is essential in spotting the red flags in the first place. In short, the financial community and the private banks dealing with so much wealth have a collective responsibility to drive AML forward and to truly fight these persistent criminal elements head-on.
With the introduction of this targeted training, UBP is setting the bar extremely high when meeting both their staff development needs and the broader regulatory requirements.
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