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2.4.1.1 Financial crime risk

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Financial crime risk combines the risk of failing to prevent offenses related to financial crimes, such as money laundering, terrorist financing, fraud, bribery and corruption as well as insider trading. This risk type is high on the agenda of regulators and one of the core responsibilities of a bank’s compliance function.

The International Compliance Association (ICA) defines financial crimes as two different types of conduct:

“First, there are those activities that dishonestly generate wealth for those engaged in the conduct in question. […] Second, there are also financial crimes that do not involve the dishonest taking of a benefit, but that protect a benefit that has already been obtained or to facilitate the taking of such benefit.”[36]

In the US, the OCC describes financial crime as ranging “from fairly simple operations carried out by individuals or small groups to highly sophisticated rings seeking funding for criminal enterprises or terrorism.”[37]

There are several sub-categories of financial crime risks.

Non-financial Risk Management in the Financial Industry

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