KPMG Research on Gatekeeper Role Bottlenecks

Divergent interests = Balance between commercial interests and preventing financial crimes Conflicting laws and regulations = Issues arising from contradictory legal requirements Limited government support = Lack of assistance from governmental authorities Being under the magnifying glass of the regulator = Facing intense scrutiny from regulatory bodies

Existential split = Struggle between organizational success and regulatory compliance Reputational damage = Harm to an organization's public image Unusual and suspicious transactions = Activities that raise red flags for potential financial crimes Commercial interests = Focus on financial success and profitability

High fines from regulators = Financial penalties imposed by regulatory authorities Involvement in financial crime = Negative consequences of being associated with illicit financial activities Significant role of commercial interests = Influence of profit motives on decision-making processes Reporting unusual transactions = Responsibility to flag potentially illicit activities

Legal requirements = Primary focus on gatekeepers Data circularity and data-mutualization = Repeated use of data and ability to update and optimize Joint transaction monitoring = More insight through network analysis Collaboration between gatekeepers = Increases quality and reliability of data

Proactive sharing of information = About customers who may pose a threat Joint facilities related to customer due diligence process = Main goal of making investigations more efficient Consent of the client = For joint data processing Information sharing between gatekeepers = On a need-to-know basis

Common understanding of legal requirements = Associated data points and required documentation Alert system for gatekeepers = Allows proactive sharing of information about threatening customers Joint facilities enable gatekeepers to form networks = Leading to more effective and efficient operations Client investigations run more smoothly = Due to repeated use of data and optimized information

More targeted identification of unusual behavior = Through network analysis Improved efficiency in transaction monitoring process = Cost reduction through joint development and maintenance of tools Improved risk management = Through more insight gained than individual banks can provide Data sharing agreements recorded in writing = For effective protection of personal data

Increased quality and reliability of data = For gatekeepers Clients do not have to undergo repeated requests = Client investigations run more smoothly Minimal data sharing between gatekeepers = Shared only on a need-to-know basis Data processing done only with client consent = Ensuring client privacy perspective

Commercial interests = Focus on profitability and business growth Prevention of financial crimes = Efforts to stop money laundering and terrorist financing Gatekeepers = Entities responsible for preventing financial crimes Compliance departments = Departments ensuring adherence to laws and regulations

Sustainability, climate, health, human rights, and good governance = Broader societal expectations Administrative burden and compliance costs = Perceived challenges of AML legislation Quality and quantity of personnel and technological resources = Factors for detecting irregularities Information sharing among gatekeepers = Obstacle due to commercial pressure

Smaller gatekeepers = Greater commercial pressures due to limited resources Insufficient support from the government = Lack of guidance and feedback for gatekeepers Imbalance in obligations, powers, and responsibilities = Result of unclear communication among government organizations Legal action against gatekeepers = Risk if not fulfilling gatekeeper role adequately

Cooperation among gatekeepers at all levels = Key for improving anti-money laundering efforts Mutual trust and knowledge exchange = Basis for initiatives among gatekeepers Common Know Your Customer taxonomy = Initiative for improving efficiency in AML efforts Setting up alert systems = Strategy for enhancing effectiveness in AML efforts

Cases of gatekeepers being criminally prosecuted = Result of inadequately fulfilling gatekeeping obligations Lack of clear ownership and direction in government = Challenge in anti-money laundering policy implementation Insufficient communication among government organizations = Issue leading to unclear anti-money laundering priorities Streamlining communication to private sector = Importance for clear communication regarding AML policies