Fight Against Money Laundering -3

The directive strengthens the other hand the obligation to share information. The Financial Security Act of 2001 introduced the need for coordination among banking groups the fight against money laundering. This involves organizing the different entities of the group exchange of information necessary for monitoring the customer on a consolidated basis. With the third directive, banks will now have the opportunity to share information between groups and banking networks, institutions and even between non-group members, since they are subject to equivalent obligations.

Beyond measures of intra and intergroup, banks must comply with in 2008 a major European regulations, European harmonization of retail payments (SEPA - Single European Payment Area [6]). "Europeanization" of cash flows increases the need for more secure against the practices of money laundering or terrorist financing. In addition to a larger volume, banks will soon face severe regulatory constraints on compliance, security and traceability of financial flows.

The banks have already set up systems for monitoring and tracking capabilities including data collection (to detect and select unusual or suspicious transactions), but also reporting and archiving of tests conducted. Examination of the flow from the source of transactions, to verify the source of funds, is based on two main areas:

* Filtering: detecting the presence or absence in the black lists published by national and supranational regulation;
* And behavioral analysis: analysis of accounts and transactions in connection with the risk profiles to detect unusual transactions and suspicious behavior.

However, with the increasing internationalization of flows and extensive monitoring obligations to the beneficial owner of the transaction, major efforts are still needed to harmonize procedures for risk prevention (warning indicators adapted from the Know Your Customer rules, ... ) internationally. According to a KPMG study [7], although the expenses of banks in combating money laundering and terrorist financing have increased on average by 58% over the past three years, only 24% of international banks have at the moment of an effective system for monitoring transactions and accounts of the same customer across different countries ...

In conclusion, the successful implementation of the Directive is closely linked to be the ability of banks to develop a coordinated approach and a risk, for realism and efficiency.

Fight Against Money Laundering -2

The scope of due diligence, previously limited to the financial sector now includes notaries, lawyers, accountants, auditors, tax advisers, estate agents, casinos, service companies and trusts, and insurance intermediaries . Monitoring the client is also extended to (s) recipient (s) number (s) [5] of the transaction: this additional requirement of identification, which seems difficult to implement, more complex work of banks.


The duty of care is now adjusted according to the risk that the client is. Each institution will define the level and nature of audit to be implemented towards the customer (identification and verification of identity on the basis of documentary evidence, gathering information on the purpose and nature of the relationship of business, followed by the business relationship ...) depending on the nature of its clientele, operation and services. The approach could also requires banks to be able to justify the adjustment of the audit.


To avoid duplication of identification procedures, the third directive sets up the principle of mutual recognition and acceptance of measurement results to identify clients: it allows the presentation of clients whose identification measures were carried out by banks and financial institutions located in the European Union. The ultimate responsibility then rests on the establishment to which the customer is introduced, that is to say the one who resorts to colleagues.


Banks have gradually established since the 1990s services fight against money laundering. They now emphasize the need for a group.

The first challenge for financial institutions is to continuously develop the culture of anti-money laundering with the group, and the training of employees by raising awareness (transmission of procedures and corresponding obligations, formation of the entire profession with warning indicators, lead to detect suspected cases ...). FBF offers on this since 2003, with the participation of Tracfin, a training evolution available to the entire profession, and consists of an awareness module and several modules specialized on specific issues.

Fight Against Money Laundering

The international community has placed first among its priorities the fight against money laundering and the financing of terrorism. The 3rd Money Laundering Directive, published October 26, 2005 in the Journal. Official European Union must be transposed into national law by 15 December 2007. Repealing the previous guidelines, it represents an opportunity to clarify the text, and seeks to strengthen international cooperation and to transpose the new forty FATF recommendations.

The third directive has several developments in four major areas: the scope, due diligence and reporting, and enforcement. A considerable broadening of the scope of the declaration of suspicion ...
The scope of the crackdown, which covered the laundering of proceeds of crime, is now extended to offenses classified as "serious" fraud (especially taxes), corruption, and especially the financing of terrorism offenses and exposing them to a sentence of imprisonment exceeding one year. These last two points are particularly sensitive:

* One hand, terrorist financing differs from money in two aspects: it is usually based on a darkening own money, and it is not the source is at issue, but the destination of the funds (often low);
* On the other hand, if the French legislation does not change, the new definition of the offense would expand the scope of all economic and financial crimes, which would lead to increase reports of suspicious and blocking and Tracking.

Goldman Sachs implicated in the scandal of foreclosures

The U.S. Federal Reserve (FED), Central Bank of the United States said Thursday it planned http://www.blogger.com/img/blank.gifto impose a fine on the U.S. bank Goldman Sachs for "malpractice" of its subsidiary, Litton Loan Servicing. The scandal of foreclosures has not finished talking to him ...

Even if Goldman Sachs has sold Monday the company involved in a huge scandal, however, the Fed has insisted that the bank "will be responsible for payment" of any fine inflicted by the Fed. In April, US regulators have reminded fourteen U.S. financial groups involved in the scandal, including Bank of America, Citibank, JPMorgan Chase, PNC and Wells Fargo, and a subsidiary of the insurer MetLife and British bank HSBC. But include Goldman Sachs at that time. But now, the Fed believes that Litton has made him as guilty of "negligence", "malpractice" and other "misconduct".

The scandal erupted late foreclosures in September 2010, driven by the controversy over the signatures so-called "robo signing" (acceptance almost to the chain of files without any real data verification) situation that led Bank of America, JP Morgan Chase and Ally Financial to suspend their proceedings.

Recall that the number of foreclosures implemented by banks in the United States reached a new record in August 2010. Financial institutions seeking so to "catch up" accumulated in the processing of cases in mortgage trouble. Banks seized 95 364 units during this period, exceeding 2% the previous record set in May The number of entry procedures performed had increased by 3% over one month and 25% in annual slippery.

In an attempt to redress the balance, the Fed imposed Thursday at Goldman Sachs to conduct an independent audit of all procedures that were being seized in Litton in 2009 or 2010 to determine the amount of financial damage caused to the borrowers.

Advertising Phenomenon of Banks-2

In addition to information about banking services offered, the campaign is primarily aimed at reconciling the public with a bank somewhat tumultuous past. The thrust of this campaign is the proximity to the client, which is accentuated by the presence of personalities that can relate to the public.

This campaign LCL echoes the concept of advertising sagas very popular with banks and has been for several years as the saga animal or the saga of popular songs. The heart of this strategy is the repetition of messages for the purpose of funding through the public ownership of the characteristics of the saga. Indeed, more than a product, banks sell a brand. The sagas advertising contribute to highlight the image of banks by creating an emotional connection, whether emotional or humorous, with the public.


If households are still the main targets of advertising campaigns for retail banks, however, there is an interest of more and stronger for the youth market, which results in the development of many advertisements. This is the case, for example, BNP Paribas, which has appealed to actors Eric and Ramzy, with its campaign focused on "helping hand". This solicitation is mainly due to the potential in the medium - long-term youth, namely 16-25 years. Indeed, it is at this age that form the first major projects (driver's license, first home ...), all of the credit for the development. The main objective is to develop a relationship over time. However, because of extreme competition, the conquest of the young results in a real war of marketing, resulting in intense communication plans and the introduction of banking products more innovative.


If we can hardly imagine today the end of the bank advertising on traditional media (television, press, radio ...), new media technologies encourage banks to renew their strategy. By winning the French advertising landscape, the Net is very popular among retail banks. Indeed, the Web has attracted over the past five years more than 10% of investment banks and retail are among the first sectors in terms of advertising presence online. The Net is also the location of new innovations in communication as demonstrated by example the concept "If I were a banker" launched by Credit Mutual and allowing the public to issue directly, via a dedicated website, needs in terms of banking services. These new approaches, focusing mainly on the interaction client / bank, pose new challenges to communication faced by banking groups. Moreover, some entities not known to the general public, such as establishments for the management of debt, have understood this opportunity offered by Internet to talk about them. Similarly banks "soft" as ING Direct or credit specialists online as Cofidis continue to develop their advertising strategy and sponsorship on the Web, demonstrate once again the health of the channel and its emergence.