This is a terrific step forward in curbing money laundering and terrorism financing in a region that has seen bad press recently. Some considerations on what to do once information sharing processes begin include:

  • Creating and maintaining a centralized database of all persons and entities cleared to conduct business across participating financial institutions (FIs)
  • Sharing Customer Identification Program (CIP), customer due diligence (CDD), enhanced due diligence (EDD) information for risk review
  • Updating databases with relevant information acquired through suspicious activity reporting, sanctions, criminal records and FI monitoring reports (transactions, updated data), etc.
  • Maintaining persons and entity risk ratings based on shared transaction activity
  • Investigating and assessing beneficial ownership
  • Investigating and assessing correspondent relationships and related risk
  • Conducting periodic file reviews and risk assessments every 12 to 36 months (based on risk profiles)