For a country to combat financial crimes effectively, it must have a comprehensive system in place, including a sound regulatory and oversight framework, an effective financial intelligence unit and a strong law enforcement and criminal justice apparatus that aligns with evolving global standards and expectations for anti-money laundering/combating the financing of terrorism (AML/CFT), sanctions compliance, anti-bribery/corruption, and counter-proliferation financing.
We have played an instrumental role in developing, implementing, and assessing compliance with the Financial Action Task Force (FATF) global standards. We are uniquely positioned to advise and assist jurisdictional clients further develop and effectively implement their AML/CFT regimes.
Strengthening CFT Regimes
K2 Integrity is uniquely positioned to assist jurisdictions and private sector institutions in strengthening CFT regimes and systems. Our team is comprised of a peerless cadre of individuals who helped design and spearhead the post-9/11 CFT regime in the United States and globally, including through senior leadership positions at the FATF, the Egmont Group, the United States National Security Council, The White House, and the United States Department of the Treasury’s Office of Terrorism and Financial Intelligence (TFI).
K2 Integrity conducts jurisdictional terrorist financing risk assessments to improve and update the understanding of terrorist financing-specific risks. Our firm supports the development of national CFT strategies, the drafting of CFT laws and regulations, the establishment of effective asset freezing mechanisms, and the development of domestic sanctions regimes.
FATF Mutual Evaluation Preparation
For jurisdictions preparing for a FATF mutual evaluation, we work with the relevant competent authorities to ensure that the implementation and effectiveness of their AML/CFT measures meet the strict peer review requirements. We work with jurisdictions to stress test their systems through a legal and regulatory gap analysis and simulated mutual evaluations and then perform legal and regulatory technical remediation for any identified areas of weakness. To support a successful evaluation, we also help develop agency-specific action plans, set up interagency working groups, organize and systematize statistics and additional documentation to demonstrate effectiveness, and provide mutual evaluation-specific training. We also remain close to the national coordinator as trusted advisors throughout the entire process.
FATF Mutual Evaluation Remediation
For any technical and effectiveness deficiencies identified through the FATF evaluation process, we work with the jurisdiction to address and overcome identified shortcomings following the FATF assessors’ recommended actions. Should the jurisdiction be required to face an enhanced follow up process or an ICRG process, we assist the competent authorities in implementing recommendations and agreed action plans. We also support them in preparing reports and defending the jurisdiction’s progress throughout the process.
AML/CFT Inter-agency Governance
K2 Integrity assists jurisdictions in strengthening their inter-agency governance processes to improve efficiency and effectiveness. We conduct assessments of the existing governance models of national AML/CFT eco-systems and propose recommendations accordingly. We help design and implement the most appropriate structures and mechanisms to guarantee an effective coordination, both at the policy development and operational levels. We also support the empowerment of national coordinators that represent their respective jurisdictions at the FATF/FSRB levels.
Risk Assessments and Strategic Alignments of Existing Regulatory Frameworks
We work with jurisdictions to help them assess and understand their money laundering and terrorist financing risks and identify areas for enhancement of their legal and regulatory frameworks using a risk-based approach. Upon completing the risk assessments and identifying existing gaps, we support jurisdictions by designing and implementing regulatory alignment strategies in accordance with the FATF standards. We also assist supervisory authorities in developing risk-based supervisory strategies and the necessary structures and tools to implement them. In coordination with designated competent authorities, we also help them clarify their roles and responsibilities with regard to AML/CFT and sanctions policies, administration and enforcement.
Strategic Advisory Services to Jurisdictions
K2 Integrity assists jurisdictional authorities in developing or refining AML/CFT strategies that anticipate or respond to key developments impacting clients’ financial integrity risks. We advise on matters involving financial integrity and remain on call to respond to inquiries, support crisis response, and provide oral briefings or written assessments. We also provide strategic technological services, assisting governments in the development and delivery of counter illicit financing utilities that help increase efficiencies within the relevant government agencies and in their relationships with the private sector.
Financial Intelligence Units
A Financial Intelligence Unit (FIU) is an essential cornerstone in the fight against the full spectrum of financial crimes. Our team of AML/CFT experts from both the public and private sector, assists jurisdictions in the design, establishment, and maintenance of FIUs that effectively collect, analyze, maintain and disseminate information from suspicious transaction reports. We offer a flexible and tailored approach based on the needs of the jurisdiction, from institutional design and organization and ongoing operational support, to capacity building and IT development.
Capacity Building and Training
A critical element to establishing a strong AML/CFT regime that meets international standards, is the development of a culture of compliance among regulatory and agency authorities. We support jurisdictions in this task by providing in training through user-friendly learning materials as well as helpful tools and analysis, either in-person or through our DOLFIN (Dedicated On-line Financial Integrity Network) platform, to ensure that the established regime is properly implemented and enforced.