Tell us a bit about your background, describe your current role and your responsibilities
Started as a deputy public prosecutor in Singapore, and then moved to private legal practice. In 2000, left as a litigation partner to pursue a Masters in Law with Columbia Law School in New York. Then joined the United Nations Compensation Commission in Geneva as a senior legal officer to review and recommend compensation awards to those affected by Iraq’s invasion and occupation of Kuwait (1990-1991). In 2005, decided to move into the financial industry and joined Citi Private Bank in Singapore. Started as AML Compliance Officer developing global AML/CFT policies and then undertook a 3-year stint as Internal Audit with Citi. In 2013, I joined Standard Chartered Bank, Singapore as the Country Head of Financial Crime Compliance. Then returned to Private Bank when I joined Bank Julius Baer, Singapore as Head of AML/KYC Compliance.
Since 2009, I have been supporting ACAMS. ACAMS is the largest international membership organization dedicated to enhancing the knowledge and skills of AML and financial crime prevention professionals from a wide range of industries. In October 2020, I formally joined ACAMS as the Regional AML Director-APAC. As the AML/CFT Subject Matter Expert (SME) for APAC, I am part of ACAMS Thought Leadership in partnering with the financial communities towards effective AntiFinancial Crime measures. I develop and deliver AML/ CFT trainings, support the organisation of ACAMS’ events and product development.
What is the Most Rewarding Part of Your Role?
Being part of the Thought Leadership on AML/CFT, in shaping and guiding the conversation in the financial community on effective Anti-Financial Crime (AFC) Risk management. I especially enjoy Capacity Building – teaching and showing the AFC professional on ‘how to fish’.
What is Your Opinion on AML/CFT?
Money laundering and terrorism financing through our financial systems are real. These are not hypothetical risks. But we cannot wait for a successful prosecution of the predicate crimes before we can pursue the proceeds of the crime and get the criminals. Like comprehensive fire safety controls in a building to prevent and detect a fire, we need effective AML/CFT controls now, and not run about only when there is a fire. So AML/CFT controls are the measures we now take to detect and disrupt illicit flow of funds through the financial system.
What made you interested in AML and financial crime?
I have innate sense of justice. I feel strongly that no one should be disadvantaged or exploited by others for their own ends. There is also a human face to ML/ TF. This is the face of those who are the victims of fraud, corruption and trafficking (drugs, arms, humans, wildlife). Effective AML measures ensures that the criminals do not succeed. Given my legal background, I also appreciate the rules by which we all have to play if we are to disrupt financial crime. I like this role of guardian and gatekeeper.
What is the most important thing you have learnt when it comes to AML?
The art of balancing the ML/TF risk and managing the client experience.
What are some of the biggest challenges in AML?
When the Front /Business sees the risk but does not want to make the hard decision.
What would you consider the key thing people forget or do not understand when it comes to AML?
The client. The client can no longer feign ignorance on the need for AML/CFT controls. They are not living in a ‘bubble’. Yet, they are surprised or become upset when they are required to answer questions and provide the necessary information to their financial institutions.
Also, the Business does not always see or accept their role as the 1st Line of Defence. So the internal challenge invariably comes from the Bankers who appear to espouse the cause of their customers. Both the client and the Business need to be educated on ML/TF risk awareness and doing the right thing to combat financial crime.
How do you keep up to date with all things AML?
I read online for the latest developments in international and local AML/CFT regulations and published enforcement actions. The local regulator’s circulars and the guidance issued by FATF, APG, Basel and Wolfsberg Group provide invaluable insight on emerging threats, trends, and typologies, as well as guidance on effective risk mitigation strategies. Also, I have an advantage working at ACAMS. ACAMS organises conferences, symposia, webinars and training on various current topics on AFC and we invite regulators, industry experts and senior practitioners to speak and share. So I lam continually learning.
What is the most rewarding part of working within your sector?
Meeting AFC professionals who are committed to learn and equip themselves to combat ML/TF.
What is your proudest achievement so far?
In my previous roles, I was managing teams of 20 or more AFC compliance professionals (CDD advisory, Surveillance & AML Investigations). My proudest achievements were when the more junior members of my team came to me and said: “Can we discuss this case, I am not comfortable with the customer or their account activity”. They got the risk!
Do you have an interesting example or case study to share?
There were cases where my team and I had to ‘follow the funds’. This was before the clever use of data analytics and AI. We used information available in the CDD profiles, internet, wire remittances and information in prior closed alerts, and we developed the ‘fund flow analysis’ on excel sheets. We were able to identify hidden relationships within our own bank and charted out complex network of people, banks and payments within and outside Singapore.
What do you see the future of the AML industry being in New Zealand?
Looking from the outside, the AML industry is demonstrating strong commitment and results in its AFC measures. This view has been affirmed by the FATF in its Mutual Evaluation Report (MER) for New Zealand issued in April 2021. I am sure both the public and private sectors in New Zealand are already working on the FATF’s Priority and Recommendation Actions.
Who in the AML world do you most admire?
Too many people to choose one. But they all had the same passion and generosity. They willingly shared their knowledge and expertise. In every draft policy, case, and issue that I discussed with my seniors, I learned.
How well do you think the New Zealand AML regime stacks up against other jurisdictions?
The New Zealand AML Regime has made commendable efforts towards effective AML/CFT preventive measures. Other countries would have read the FATF MER – New Zealand, and will most certainly learn how New Zealand achieved “Highly” and “Substantially” Effectiveness in 6 of the 11 FATF MER-Immediate Outcomes. New Zealand would also of course want to understand from the other countries how to achieve higher effectiveness in the remaining 5 Immediate Outcomes.
Rosalind's Top 3 Tips
1. Develop the intuition
Do you see the ML/TF risk in a given customer, product, service or transaction? If yes, articulate that risk.
2. Be creative
How can you effectively manage the risk in the given situation? Think of solutions which do not compromise compliance with the regulations /policy or the risk itself.
3. Be confident
Know your AML/CFT regulations, your policy and the risk– the ‘whats’ and the ‘whys’. Then stand strong.