Guideline for AML Reporting Content
Niemi, Maria (2021)
Niemi, Maria
2021
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Julkaisun pysyvä osoite on
https://urn.fi/URN:NBN:fi:amk-2021060213419
https://urn.fi/URN:NBN:fi:amk-2021060213419
Tiivistelmä
The case company is a bank in Northern Europe. The study focuses on internal AML reporting in Finland. Other Northern European branches of the company are out of scope, as local legislation might apply. AML reporting in thesis context is used as an umbrella term for all possible report types, such as KYC, SAR, PEP or other. The bank’s AML reporting language changed from Finnish to English in 2020. The objective was to find out the impact of language change on AML reporting content. This was chosen as the topic because the quality of reports is desired to stay high, regardless of the language. Branch Managers were given more responsibility over giving feedback on AML reports in 2020. This had previously been the responsibility of the AML department.
The study was conducted using qualitative action research methodology. Thesis Data 1-3 Collections were gathered by interviewing stakeholders. They were AML team Finland, Branch Managers in Finland and CEO in Finland. The current state analysis revealed that the language of AML reporting was not seen as a problem to report content. Based on its results and existing literature, the conceptual framework was built. The conceptual framework foundation is existing literature and best practice found from Financial Action Task Force, Financial Supervisory Authority FIN-FSA and Ministry of Finance, Finland. The most important source from literature is Finlex with AML Act 444/ 2017.
Based on current state analysis and literature search results, the initial proposal was built. Initial proposal was validated by Branch Managers and CEO Finland. The study found other factors that affect the report content more than language, such as risk assessment and not opening it in written form in the report. The reports need to answer to “who”, “what” and “why”. If risk assessment requires supporting documentation for the report, the report is not complete if this documentation is missing. The results also stress the importance of giving feedback to report writers and its connection to report quality.
The most assistance with AML reporting and its content is needed by new employees. The company can use this Guideline for AML Reporting Content alongside AML training as an addition to introduce AML reporting to its new employees. Branch Managers can use this thesis as support material to give feedback on written reports.
The study was conducted using qualitative action research methodology. Thesis Data 1-3 Collections were gathered by interviewing stakeholders. They were AML team Finland, Branch Managers in Finland and CEO in Finland. The current state analysis revealed that the language of AML reporting was not seen as a problem to report content. Based on its results and existing literature, the conceptual framework was built. The conceptual framework foundation is existing literature and best practice found from Financial Action Task Force, Financial Supervisory Authority FIN-FSA and Ministry of Finance, Finland. The most important source from literature is Finlex with AML Act 444/ 2017.
Based on current state analysis and literature search results, the initial proposal was built. Initial proposal was validated by Branch Managers and CEO Finland. The study found other factors that affect the report content more than language, such as risk assessment and not opening it in written form in the report. The reports need to answer to “who”, “what” and “why”. If risk assessment requires supporting documentation for the report, the report is not complete if this documentation is missing. The results also stress the importance of giving feedback to report writers and its connection to report quality.
The most assistance with AML reporting and its content is needed by new employees. The company can use this Guideline for AML Reporting Content alongside AML training as an addition to introduce AML reporting to its new employees. Branch Managers can use this thesis as support material to give feedback on written reports.