KPMG's Research on Gatekeeper Role: Bottlenecks and Improvement Suggestions

The bottlenecks identified in the KPMG report include excessive government support.

Gatekeepers are not influenced by commercial interests in their decisions to report suspicious transactions.

'The existential split' refers to the delicate balance between commercial interests and public interest in preventing financial crimes.

Reputational damage is not a concern for organizations involved in financial crimes.

Gatekeepers must consider not only preventing financial crimes, but also broader societal expectations such as sustainability, climate, health, human rights, and good governance.

Smaller gatekeepers may experience less commercial pressures due to their dependence on a larger client base.

Gatekeepers perceive the administrative burden and compliance costs of Anti-Money Laundering (AML) legislation as insignificant.

It is always clear when an institution has sufficient quality and quantity of personnel and technological resources to detect irregularities.

Commercial pressure does not hinder information sharing among gatekeepers.

Gatekeepers receive sufficient support from the government to perform their role effectively according to interviews conducted by KPMG.

There is clear ownership and direction regarding anti-money laundering and sanctions policy due to streamlined communication between government organizations.

Gatekeepers have faced legal action even if they were directly involved in money laundering or terrorist financing.

Sharing knowledge among different categories of gatekeepers is considered essential for improving money laundering and sanctions Act efforts.

Developing a common Know Your Customer taxonomy is not listed as one of the possible solutions provided by KPMG to improve efficiency and effectiveness.

Gatekeepers must comply with a variety of sources such as laws, regulations, guidelines, and guidance from international organizations like FATF.

Gatekeepers' policies and processes are standardized and consistent due to the consistent requirements across all sources.

Gatekeepers may request different documents and data points from clients based on their interpretation of compliance requirements.

A shared Know Your Customer taxonomy involves a common understanding of legal requirements but excludes data points and required documentation.

The Protocol Incident Alert System Financial Institutions (P.I.F.I) facilitates sharing information about customers who may pose a threat to other gatekeepers.

Joint facilities among gatekeepers aim to make the investigation of clients more challenging by limiting data sharing.

Collaboration between gatekeepers enhances the quality and reliability of data for gatekeepers and clients alike.

Joint facilities related to customer due diligence processes focus on restricting client investigations rather than enhancing efficiency.

Client privacy is not taken into account when gatekeepers engage in structured data sharing for joint facilities.

Gatekeepers are encouraged to share information about clients freely without client consent for the sake of efficient operations.