Financial Competencies in Combating Money Laundering in the Banking Market

Abstract

The work is devoted to the theoretical justification and development of tools for evaluation of internal anti-money laundering factors. For this purpose the following tasks are set and solved: a set of internal bank factors of counteraction to money laundering is substantiated; tools for evaluation of internal banking system to counteract money laundering have been developed; the developed tools with the involvement of experts of seven operating banks of Ukraine have been tested. The internal bank anti-money laundering factors are structured by the following groups: client-related, operational, and systemic. Client-related factors reflect the type of activity, beneficial owners, and purpose of opening bank accounts. Operational factors within the legal economy allow assessing the amount of cash in the country, volume of cash transactions of banks, availability of any anonymous transactions in banks and transactions with cryptocurrencies. Systemic factors cover the issues of staff competence and training, compliance, bank information systems management, corporate governance, document and information storage, and internal control and audit. Internal banking anti-money laundering factors were assessed using the developed tools, which include: questionnaires to assess the competence and training of staff, information systems management, compliance, internal control and audit, documents and information storage, corporate governance; ans scoring of possible answers. The evaluation of these factors performed according to seven banks of Ukraine established that compliance is the factor that least corresponds to the most favorable situation for the three banks, for two banks it was competence and training of staff, for other banks - internal control and audit, corporate governance and role of its bodies.