by Mandy Ramlow, Director, VP, U.S. AML Financial Intelligence Unit, BMO Harris Bank N.A.
Interview ahead of Fraud and Financial Crime USA Congress, taking place March 27-28 in New York City
*Disclaimer: The opinions in this article are of my own, and not that of my company*
Can you please tell the Risk Insights readers a little bit about yourself, your experiences and what your current professional focus is?
I am currently the Director of the AML Financial Intelligence Unit for a US institution that has oversight for transaction monitoring for suspicious activity (filing SARs), monitoring of high risk customers, filing CTRs, working with law enforcement when they have requests, and AML closures. Through the course of my 23 years in banking, 14 have been in AML with a key focus on operating FIUs, but also developing suspicious activity transaction monitoring approaches, in addition to finding more efficient and effective ways to operate within the AML business model, without compromising on risk.
What, for you, are the benefits of attending a conference like the Fraud and Financial Crime USA Congress and what can attendees expect to learn from your session?
The benefits of attending sessions like these, is the networking and learnings that you take away from the speakers and panelists sharing their best practices and ideas. While each topic may not fit your business model or risk tolerance, you always walk away with a few points of interest that help you push your thinking on AML and how to conduct your program. What I hope attendees learn from my session is the capabilities around the sharing of information, but also what I have learnt or developed as best practices with my teams when sharing information. In addition to the limitations, and how we are trying to work through those road blocks as an institution and with our law enforcement partners.
In your opinion, what are the benefits and challenges of increasing intelligence sharing between law enforcement, regulators and banks? How do tight privacy laws across borders restrict collaboration?
The key benefit of sharing between law enforcement, regulators and banks, is the knowledge of the greater risk. When you work in one silo, and you don’t have all the intelligence you can be missing all the risks to your institution. Information moving both directions is helpful not only to be reactive but proactive to the risks that others are seeing, that maybe have not been on your radar. In regard to tight privacy laws across borders, it does make things challenging, but the capabilities are not impossible with the right controls, restrictions and role accountabilities on who can have access to certain information. You also need a good internal legal and governance partner, to help you document the approach.
What are the key considerations that need to be made when seeking to achieve pro-active intelligence gathering approach?
Who are your partners, what data you have available that can be shared, and then how do you share that information and include it in your investigations? The ingestion of the information and sharing of the information internally within your company versus how you can share externally with others in your network, should be considered to proactively identify risks within your customer base.
How can institutions ensure effective information sharing to boost prevention of fraud & Financial Crime?
Good stakeholder relationships, tangible data, strong controls and good governance.
How do you see the impact of Fraud and Financial Crime evolving over the next 6-12 months?
Data, analytics, machine learning, AI, robotics, will continue to transform our fraud and AML space on new ways to run our programs. However, just as important will be how we Integrate this technology into our programs, the governance required and if our regulatory partners, set new expectations around the use of these tools.