AML challenges and risks in the Baltics

ACAMS Baltic Chapter – Inaugural Estonia Event

The ACAMS Baltic Chapter conference focused on the money laundering (ML) and terrorism financing (TF) challenges and risks in the Baltics. Such as regulatory collaboration, increased regulatory oversight, emerging risks and when can we expect transnational legal frameworks. Various field specialists addressed the aforementioned topics and compared the challenges and risks in the Baltics in practice and in theory.

Jānis Brazovskis, Board Member of the Latvian FIU, opened with a quote from Mr Valdis Dombrovskis who has said that anti-money laundering (AML) regulations should be as uniform as possible, but as theoretical as necessary. It was a pleasure to hear that Latvia is one of the few countries that were the first to support transnational regulations. Furthermore, Mr Brazovskis emphasized that the ML combatting system in Latvia has been rebuilt during the past year and that Latvia is the first country in the continental Europe to have a public private information sharing partnership.

Matis Maeker, Head of AML/CFT and PSP Supervision Department of the Estonian FSA, addressed the issue from a different perspective by posing a question – why don’t we see that money launderers, the perpetrators are being penalized? Why do we only see that the supervising authorities, the payment institutions and etc. are being penalized? Mr Maeker holds a view that it is about law enforcement and proposes to help each other identify risks and not only focus on the payment services, but on the money flow itself.

Sandijs Vectēvs, Deputy Head of the Latvian FIU, on the other hand said that the money launderers are not smart enough to create the ML scheme themselves, meaning that the institutions and so to say ML service providers are the ones making up the scheme (intentionally or unintentionally), therefore the focus should be on the institutions. I should add that one of the emerging risks in ML is ML being offered as a service.  

Recently there has been a significant focus on the Baltic States in regard to ML and we may ask – why us? But as John Wilkinson, EY Partner, Global Transactions Forensics Leader, said –  we are not the first region and one of the reasons may be as simple as our geographical location.

We, as the Baltics and as Latvia, are moving forward with combatting ML. And as we move forward, we keep facing new challenges. Therefore it is important to educate the society and also for the businesses to get as involved as possible, adapt to new requirements and see the bigger picture and meaning behind the endless regulatory requirements that may seem too bureaucratic.

by Elīza Grīnvalde, AML specialist (CAMS), Latvia

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