ACAMS Interview Series
Why use RegTechs for Financial Crime Compliance? - Part 1 with Jeremy Moller
Tell me about your background in financial crime compliance?
I am a financial crime compliance lawyer in Norton Rose Fulbright’s Risk Advisory Team based in Sydney. I have been specialising in anti-money laundering, international sanctions and foreign transparency for over 10 years. I have previously worked in regulatory compliance roles advising entities both internally and externally on their approach to combating financial crime.
I currently assist in implementing and reviewing financial crime programs, as well as advising on litigation arising out of regulatory investigations and acting on Royal Commissions. I also have experience working with a range of regulators both in Australia and overseas, including with the Australian Transaction and Reports and Analysis Centre (AUSTRAC).
What challenges has Covid-19 placed on financial crime compliance resourcing?
15,000 entities in Australia are required to report to AUSTRAC. This doesn’t include lawyers, accountants and real estate agencies who may soon become regulated under AML laws. If this occurs that number will increase to over 100,000.
There is a significant demand for talented individuals, however with migration restricted, there is simply not the volume or experience in the market to meet all the resource demands needed for new projects and the increasing day-to-day requirements. This has seen a greater reliance on RegTech’s to support the needs of reporting entities in meeting their obligations.
Why else do you think there is an increasing demand for RegTechs?
RegTech’s offer some great solutions to client’s problems. There is such a reliance on technology, which means there is almost a necessity for regulated entities to partner with RegTechs. Working with RegTechs enables them to quickly move away from legacy systems and keep pace with market practice and regulatory demands.
RegTech’s bring a diverse skillset and market leading innovation which can benefit reporting entities as these resources would otherwise be too costly to create and maintain internally. There are also efficiencies in moving to an external provider/system due to the economies of scale, speed of implementation and service levels that can be delivered.
How can companies identify which RegTech solution is right for them?
Australia is the third largest RegTech market in the world so there’s lots of choice however, the three key questions that any regulated entity should be considering when assessing a potential RegTech product are:
- What problem are you trying to solve?
Understand what each product is looking to do, such as a risk assessment tool, screening product, or like Identitii’s which assists with reporting to regulators.
- Who are the key stakeholders and decision makers that need to be involved in the process?
Involve multiple stakeholders in the assessment and implementation of a product. This should include the financial crime compliance team, the front-line business, IT, legal and project managers to guide the process.
- How do they ensure that implementation is as successful as possible, but also that there is a plan to maintain and improve the product over its lifecycle?
Always seek advice to understand if the RegTech product being implemented meets legal and regulatory requirements. This should include a regular periodic review.
RegTech products are a great tool if used successfully, but can create issues if the planning, design, implementation, and maintenance is not prioritised. We always suggest that reporting entities seek the necessary external advice to assist with these elements.
You’re attending the Association of Certified Anti-Money Laundering Specialists (ACAMS) Conference in Sydney this month, what are you looking forward to most?
First of all it will great to be able to communicate and network for one of the first times in over a year. I am also looking forward to moderating the panel on ‘Emerging Threats to your Financial Institution’s Risk Assessment’ for which Identitii’s CEO John Rayment will be a panellist.
If you would discuss your financial crime compliance further or meet at the ACAMS conference…