AML/CFT - The Risk Based Approach

The risk-based approach is central to the effective implementation of a Subject Person’s AML/CFT obligations. It aims to support the development of preventative and mitigating measures that are commensurate with the money laundering and funding of terrorism risks identified by the Subject Person, and to deal with those risks in the most cost-effective and proportionate way.

Adopting a risk-based approach to mitigating and managing money laundering and funding of terrorism risks allows Subject Persons to focus on the outcomes that the Prevention of Money Laundering & Funding of Terrorism Regulations (PMLFTR) intended to achieve. That is, preventing money laundering, terrorism financing and other serious financial crimes, rather than complying with a checklist of requirements.

From a Subject Person perspective, risk assessments are conducted at several levels. These include the:

• Business Risk Assessment (BRA);
• Customer Risk Assessment (CRA); and
• Jurisdiction Risk Assessment (JRA).

The two-day session will delve into each of these risk assessments, outlining the legal framework and detailing the salient obligations imposed on Subject Persons. The presentations will also deal with the practicalities of designing appropriate risk assessment methodologies that are effective and in line with regulatory expectations.

During the presentations, the salient details on the EU’s Supranational Risk Assessment (SNRA) and the local National Risk Assessment (NRA) will be delineated, discussing how these can be integrated into the Subject Person’s risk framework.

The Speaker

Antonio Ghirlando is a seasoned compliance specialist with a specific focus on financial crime compliance, including the prevention of money laundering, countering the funding of terrorism, combatting proliferation finance, sanctions, anti-bribery & corruption, and fraud. He is also well versed in other regulatory compliance obligations.

Antonio is actively involved in the provision of real-time operational support, specialist advice, intuitive guidance and training to several businesses seeking to ensure ongoing compliance with their regulatory obligations. He also assists Money Laundering Reporting Officers (MLROs) and Compliance Officers with their day-to-day tasks and oversight.

During his career he has worked with various licensed entities in both the financial and non-financial sectors, having served as the Head of Compliance, Head of Financial Crime Compliance, Money Laundering Reporting Officer (MLRO) and Data Protection Officer (DPO). He also headed the Compliance and Legal & International Sections of the Financial Intelligence Analysis Unit (FIAU) and served as the Secretary General of the Malta Bankers’ Association (MBA).

Antonio has been involved in several local and international committees, and has also presented numerous papers at various workshops, seminars, conferences and training events. Antonio is a graduate of the University of the Witwatersrand in Johannesburg, South Africa.