Q1: Kenneth, thank you for taking the time to speak with us. Please can you tell our readers a little bit about yourself, your professional experience, and your current focus?
After years in telecommunication sales, marketing, and operations, I entered the retail space as a money transfer remitter, where I learned about anti-money laundering risk and controls. After the stores were sold, I became an AML and Sanctions consultant for FIS, the nation’s premier Fintech company for small/medium banks. In 2012, Nordea Bank, the largest regional Nordic bank, hired me to take my compliance knowledge to start a third party risk management program at the New York branch. I am now part of the world-wide rollout of TPRM for the bank.
Q2: You will be delivering a presentation based around the role of the vendor and third party risk manager in sanctions and financial crime prevention . Why do you believe this is an important talking point?
We are all compliance! Vendors receive payments, and all payments carry risk for financial institutions. Knowing how to recognize and escalate suspicious behaviour is key to helping prevent financial crime.
Q3: What county rules and requirements must vendor and third party risk managers be aware of?
Sanctions are country specific. There are US (OFAC) sanctions as well as BIS export restrictions. There are limited sanctions that prohibit certain industries or persons from receiving payments. Anti money laundering scenarios are risk based. Payments in/out of certain countries increase the AML risk.
Q4: How can vendor and third party risk professionals best identify unusual payments, and what do you believe is their role in this process?
Vendors requesting unusual payment methods (cash, structured payments, or payments to an unknown fourth party). Vendors having accounts in countries other than where they are headquartered or performing the service.