IIF and Deloitte Release White Paper on Addressing Financial Crime More Effectively

November 15, 2021

WASHINGTON, D.C. – Today, the Institute of International Finance (IIF) and Deloitte released a new white paper showing key areas where continued reform could help improve the effectiveness of the global anti-financial crime framework in the wake of the COVID-19 pandemic, changing patterns in financial crime risk, and efforts underway to transform the system.

“Stakeholders across the public and private sectors need to work together to provide strong global leadership on the issue of financial crime,” said Andres Portilla, IIF Managing Director of Regulatory Affairs. “Only by working in a coordinated fashion internationally can we address, mitigate and ultimately prevent illicit financial flows.”

“Efforts to better align the objectives, focus and resources dedicated to fighting financial crime across the public and private sectors are critical to promoting a more risk-based, innovative and outcomes-oriented approach to combatting it,” said Clint Stinger, principal at Deloitte Transactions and Business Analytics LLP and Deloitte’s US AML and Sanctions Services Leader.  “We’re hopeful this new paper can help all participants consider areas for continued improvement.”

New challenges continue to arise for the public and private sectors in addressing financial crime. For example, in the past year, public financing for pandemic recovery programs has created new potential for criminal abuse. Public-sector financing for climate initiatives has also increased and presents similar challenges. These factors, among others, show a pressing need for an updated view on how to combat the criminal misuse of the financial system.

This new paper highlights four key areas of focus for continued reform:

  1. The use of financial intelligence -- supporting Suspicious Activity Reporting (SAR) reform, improved beneficial ownership transparency, and increased public private partnerships between law enforcement, regulators and financial institutions to better target risk and mitigate cross-border financial crime
  2. Risk prioritization -- introducing national priorities and associated changes to supervisory expectations to help regulated institutions focus financial crime risk management programs on a more risk-based, outcomes-oriented approach
  3. Technology and innovation: obtaining public sector support for adopting new technologies, such as machine learning and data analytics, to enable enhancements in monitoring and detection of financial crime
  4. International cooperation and capacity building – effectively implementing international standards and building a solid foundation applying the risk-based approach can help create systemic coherence in fighting financial crime around the world


The paper also discusses how reform efforts that are underway in various countries and regions can be deployed across jurisdictions, and considerations for policymakers as they seek to better prioritize international coordination and consistency.

The recommendations outlined in the white paper are the result of a collaboration between the IIF and Deloitte and expand upon an earlier research effort from 2019 conducted with Deloitte UK, tracking progress on reform and updating issues for consideration. Both organizations conducted research and interviewed stakeholders at financial institutions and public authorities responsible for anti-money laundering (AML) or combating the financing of terrorism (CFT), as well as the wider financial crime policy and enforcement environment across both developed and emerging markets. The concepts in the paper build upon the good work currently underway through the Financial Action Task Force (FATF), other public sector bodies and the private sector in tackling this important issue.


About the Institute of International Finance (IIF)

The Institute of International Finance (IIF) is the global association of the financial industry, with more than 400 members from more than 70 countries. Its mission is to support the financial industry in the prudent management of risks; to develop sound industry practices; and to advocate for regulatory, financial and economic policies that are in the broad interests of its members and foster global financial stability and sustainable economic growth. IIF members include commercial and investment banks, asset managers, insurance companies, sovereign wealth funds, hedge funds, central banks and development banks. To learn more about IIF, please visit www.iif.com, follow us on Twitter, LinkedIn or YouTube, or check out IIF’s podcasts.


About Deloitte
Deloitte provides industry-leading audit, consulting, tax and advisory services to many of the world’s most admired brands, including nearly 90% of the Fortune 500® and more than 7,000 private companies. Our people come together for the greater good and work across the industry sectors that drive and shape today’s marketplace — delivering measurable and lasting results that help reinforce public trust in our capital markets, inspire clients to see challenges as opportunities to transform and thrive, and help lead the way toward a stronger economy and a healthier society. Deloitte is proud to be part of the largest global professional services network serving our clients in the markets that are most important to them. Building on more than 175 years of service, our network of member firms spans more than 150 countries and territories. Learn how Deloitte’s more than 345,000 people worldwide connect for impact at www.deloitte.com.

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