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Our approach and progress

2009 goals Status Achievements
Develop a specialised training programme for our money laundering prevention officers. Completed Delivered specialist training
for more than 400 country
level staff with specific money laundering prevention responsibilities.
Launch new multi-language Anti-money laundering programme for all staff. Completed Rolled out a global eLearning programme in eight key languages to improve understanding by front line staff. More than 42,000 staff completed the course this year.
Enhance the detection capability of our Norkom money laundering monitoring system. Completed Significant improvement in the effectiveness of detection scenarios, leading to an increase in the proportion of alerts converted to cases.
Assess sanctions screening systems coverage against industry best practice. Completed Using the FSA's 2009 industry report and independent external benchmark data, we have completed an assessment to help define our 2010 plan for continuous improvement.
Indentify enhancements to
our Speaking Up Programme.
Completed Developed a new programme, for launch in early 2010, providing greater accessibility to staff through web-based messaging systems and a global free-phone service in multiple languages.

2010 priorities

  • Provide additional training to front line staff in higher AML risk areas.
  • Deploy Norkom AML monitoring system to a further two countries.
  • Implement seven additional detection scenarios to identify more patterns of suspicious activity.
  • Further enhance sanctions screening systems to improve name identification and expand coverage.
  • Implement the new Speaking Up programme.
  • Increase transaction screening to improve identification of transactions with corruption risk.
  • Strengthen controls for anti-bribery in higher risk business segments.

We tackle financial crime in three ways: we minimise the risk that our products and services can be used by money launderers, we deny suspect terrorists access to our banking systems, and we build robust controls against fraud and corruption. It is a process of continuous improvement as the risks evolve and industry best practice develops.

Report tools

Annual Report and Accounts 2009