Under the Regulatory Microscope
Faced with increased regulatory demands and scrutiny in the midst of heightened regulatory enforcement, Nordic banks need to take a hard look at their AML/KYC systems and embrace a digital transformation approach to compliance. Fenergo’s Laura Glynn, Director of Regulatory Compliance, discusses.
Over the last 10 years and since the onset of the global financial crisis, Nordic banks have been trying to come to grips with a new regulatory reality, witnessed by the introduction of a raft of heightened and new regulatory demands centered around anti-money laundering (AML) and know your customer (KYC) obligations.
Some Nordic banks have already fallen prey to this increased regulatory scrutiny with the imposition of significant monetary penalties on some of the region’s leading banks. Regarding AML breaches specifically, Nordic banks have been the subject of many high-profile violations over the past few years. Indeed, over the last five years, Nordic regulators have sanctioned and fined five leading financial institutions for AML violations and offences, amounting to nearly €20 million in punitive fines, with another €1.5 million levied on Nordic banks by financial regulators outside of the Nordics region.
Many Nordic banks also got caught up in the furor caused by the high-profile and unprecedented leaks that have dominated headlines in recent years. Cases such as the Panama Papers – which saw 11.5 million documents being leaked, revealing the secret financial dealings of over 214,488 offshore entities – threw the regulatory spotlight firmly on beneficial ownership transparency and AML/KYC practices once again.
Already under pressure to grow business by acquiring new clients and increasing the wallet share of existing clients, Nordic banks are under renewed stress to ensure all of this is done compliantly, efficiently, cost-effectively and all without impacting client experience.
AML Systems Under Review
It would appear, by looking at the number and size of fines levied in the last three years alone, that the Nordic regulators are losing patience with banks over AML deficiencies, lax controls and inadequate AML/KYC systems and IT infrastructure.
In the wake of the recent high-profile money-laundering scandals outlined above, the five Nordic Financial Supervisory Authorities (FSAs) are now collaborating in a much closer fashion than ever before to share cross-border information on money-laundering threats.
They are also beginning to conduct more regular on-site compliance audits to evaluate the operational effectiveness of banks’ IT systems used to monitor, detect and report suspicious transactions and accounts to authorities.
The regulators’ unequivocal message to Nordic banks is that they need to do far more to improve their approach to AML compliance. The pressure is now firmly on banks to improve their AML-IT systems in compliance with local, European and global regulations.
However, the ability to achieve compliance throughout the client life cycle is being hampered by fragmented systems, siloed data and technological inefficiencies across Nordic financial organizations.
Transforming AML/KYC with Digitalization
What is needed is a transformational approach to AML and KYC compliance. If Nordic banks continue to do what they have always done, they can’t expect different results. In order to achieve a streamlined and consistent approach to compliance that safeguards them from regulatory exposure and allows them to focus on client experience, Nordic banks need to embrace a digital transformation process.
In part 2, we explore how financial institutions can digitalize the client life cycle process to ensure compliance, increase operational efficiency and deliver a superior client experience.
Laura Glynn, CAMS, is Director of Regulatory Compliance at Fenergo. As such, she is responsible for managing Fenergo’s Regulatory Roadmaps to ensure Fenergo clients are fully future-proofed from a compliance perspective. Laura and her team run regular Regulatory Forums with Fenergo’s global client base to translate key regulatory requirements into rules-based logic ahead of compliance deadlines. With over a decade’s experience working in the area of risk and compliance, across hedge, mutual and private equity products, Laura has cultivated a strong focus on AML and regulatory compliance. Laura is ACAMS certified and holds a B.Sc. degree in Government & Public Policy from University Collect Cork and a diploma in Applied Finance Law from the Law Society of Ireland. 
