Further Strengthening AML/CFT Frameworks Including Response to Financial Crime

AML/CFT (Anti-Money Laundering / Combating the Financing of Terrorism) frameworks have moved beyond the build phase and are now transitioning into operation, effectiveness verification, and continuous improvement. At the same time, advancements driven by requirements from the Financial Services Agency (FSA) and the National Police Agency (NPA), together with increasingly sophisticated criminal techniques enabled by digitalization, are demanding a response that goes beyond conventional frameworks.

ABeam Consulting takes an integrated approach to the three domains of "build, operate, and verify," designing multi-layered countermeasures from an enterprise-wide optimization perspective. We support cross-organizational execution that involves the 1st line^*. A specialized team led by holders of the CAMS (Certified Anti-Money Laundering Specialist) qualification provides seamless support from concept formulation through implementation and advancement, realizing a strengthened framework that achieves both effectiveness and efficiency.

* A framework based on the "Three Lines Model," consisting of business units (1st line), management and risk management functions (2nd line), and internal audit (3rd line).

In response to the FSA guidelines, financial institutions had largely completed the build-out of their AML/CFT frameworks by the end of March 2024. They are now moving into a phase that demands verification of the effectiveness of those frameworks and continuous enhancement through PDCA cycles.

In addition, with the FSA and the NPA articulating increasingly specific requirements, and against the backdrop of more sophisticated and elaborate financial crimes such as illicit money transfers and money laundering, the scope of issues that must be addressed continues to expand. In particular, the expansion of non-face-to-face transactions and the organized nature of crime mean that conventional AML/CFT measures alone are no longer sufficient, making it essential to build a comprehensive and effective risk management framework that also covers response to financial crime.

To address these challenges, it is essential to move beyond optimizing AML/CFT and financial crime response in silos. What is required is the consideration of multi-layered countermeasures from an enterprise-wide perspective, combined with integrated discussion and execution that involves the entire financial institution, including the 1st line.

ABeam Consulting goes beyond simply presenting a to-be state. We provide seamless support from concept through implementation and embedment, taking into account each client's situation and operational realities, to realize an effective framework that functions on the front lines. We design build, operation, and verification as an integrated whole, and drive the introduction of frameworks that continuously enhance effectiveness from both business and system perspectives. This includes establishing monitoring and PDCA, designing operations with an eye on advanced technologies, and integrated framework development that extends to human resource development and evaluation. A distinctive feature of our approach is the design of cross-organizational execution that involves the 1st and 2nd lines from the earliest stages of consideration.

In addition, our specialized team—led by holders of the international qualification for AML/CFT specialists, CAMS (Certified Anti-Money Laundering Specialist)—delivers support that combines deep expertise with a practical, hands-on perspective.