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Anti-money laundering and anti financial crime

The  Cappello Law Firm  offers assistance and advice on anti-money laundering and anti-financial crime.


The regulatory evolution of anti-financial crime disciplines , in combination with the current crisis scenarios, determines the need to promptly adapt to the growing responsibility of legal persons , to the dizzying technological evolution of electronic money and, last but not least, to the profound change of the financial system destined to impact every sector of economic activity and the area of competence of each subject required to comply with anti-money laundering legislation.


Change in the financial system that turns out to be whirlwind starting from the relocation of products and the relationship with customers, passing through the dizzying growth of digitization processes and the relevance of information systems with respect to areas of human evaluation, up to the increasingly changed concept of more ancient fundamentals, such as money, the role of banks and financial intermediation with a consequent redesign of the players present today in the international scenario and of the roles held up to now.


To this is added the growing regulatory weight attributed to the supervision to be exercised on subjects required to comply with anti-money laundering obligations in an increasingly community and transnational key in order to allow States and international supervisory bodies an increasingly integrated governance of risks in the financial crime context. the ever diminishing importance of territorial and political borders.


This evolution, which will be even more impactful in Italy in consideration of our consolidated system, requires supervised entities to adopt an increasingly structured approach which therefore needs to adopt more robust organizational and IT solutions than the current ones.


The Firm offers solutions that must be increasingly based on consolidated and internationally recognized standards , but at the same time must be adequately customized, with each individual obliged party, in order to avoid excessively increasing risks to be governed and costs to be incurred. .


In this context, the same banks, which until now relied on system solutions in many cases (for example Gianos) are adapting to the new European control requirements, which will soon be adopted also in Italy, and which determine increased risks of penalties and organizational costs determined by the use of complex and expensive support tools, which however do not solve the problems once installed, as has already been the case for many years in the United States, with many penalties over a billion dollars and costs dizzying people and software management.


These instances, also with reference to the covid economic scenarios and the typical aggressiveness of criminal groups in times of crisis and public funding, in fact privilege a tight control of organizational and IT approaches (for example the obligation to continuously govern a "own "Control of anomalies / alerts) in order to measure the structural impermeability of the system of the individual obliged party, instead of measuring the possible presence of accidents that may have occurred as mostly occurred in Italy up to now.


In this scenario, the Firm provides advice on the basis of the longest and most consolidated experience, with the aim of combining the best risk management by minimizing the risk of substantial and useless investments.


In this regard, the reference areas in which support at the highest levels of competence is ensured, in total harmony with the requests of the Authorities, not just Supervisory Authorities, with which we establish a fruitful relationship of continuous alignment, are shown below.


Areas of expertise in anti-money laundering / anti financial crime:


  • Support during the inspection by Italian or European supervisory authorities.

  • Consultancy following an inspection report.

  • Support on evolutionary projects  and innovative ones such as: electronic money, remote operations or the establishment of competence centers.

  • Organizational structure consultancy.

  • Advice on the information system.

  • Advice on the regulatory framework.

  • Consultancy on the company training system.

  • Consultancy on the internal control system.

  • Advice on the suspicious transaction reporting process.

  • Advice on the alert evaluation process.

  • Advice on the electronic identification process of alerts.

  • Advice on the self-assessment process.

  • Advice on the reward system.

  • Direct training for employees and corporate bodies.

  • Controls on behalf of the internal auditing function or on behalf of the board of statutory auditors.

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