Compliance Interview Series
with Anastasija Slobodenuka

Anastasija Slobodenuka, Lawyer, CAMS, PricewaterhouseCoopers Legal Law Firm

1. Could you explain the concept of money laundering in simple terms?
    In short, the money laundering is understood as the involvement in legal circulation of money and other property which is obtained from criminal activities. In particular, money, for example, received from various crimes such as corruption, drug dealing etc.
2. What is the biggest challenge in this sector?
    There are many challenges in anti-money laundering sector, but most common are
    - Identifying ultimate beneficial owners - this could be number one, because of historical issues with offshore companies and complex corporate structures that include numerous shell companies. Earlier, it was possible to hide the identity of a UBO and it was used by criminals, sanctioned persons and politically exposed persons because they could receive ‘’legal income’’, which has become such as money passed through several layers;
    - New FinTech trends and new ‘’financial crime trends’’, cybercrime variety and many loopholes in legislation (email frauds, phishing, theft of corporate data and other);
    - Differences between principle legislation and specific regulations issued on the basis of such legislation in the money laundering area, which can be quite contrasting even between countries that have adopted common guidance.
3. How can AML or KYC or KYB benefit from the blockchain technology?
    Unequivocally, the algorithms in a blockchain could help to detect fraud faster and more efficiently. Moreover, working in synergy with IT, lawyers and analysts definitely would put AML to the next level.
4. How can governments stop money laundering? What do you think, can they?
    Creating awareness and providing the additional training to the AML people (taking into account new tendences and services on a market), because it is one of the most important aspects of controlling money laundering activities.
5. If everything went to digital money and cash was no longer accepted, how will it change the AML process?
    On the one hand it would minimize fraud with cash deposits and withdrawals, but on the other hand it would force criminals to invent new ways and methods of money laundering using wire transfers and other banking products.
6. Why is money laundering bad for the economy? What is the worst effect?
    Not only that it reduces tax revenue, impact government budgets negatively and affects currencies and interest rates, it is always a complex scheme that entails unpredictable consequences.
7. What are the best books to read to learn about Anti Money Laundering? Have you got any recommendations?
    I would recommend FATF recommendations, best reading with cases and newest trends.
8. What are the risks and benefits of cryptocurrency in the AML?
    The biggest risk I would say is anonymity. Also the reputation of a cryptocurrency is not playing into the hands.
    Regarding the benefits - it is easy to invest in cryptocurrency. Additionally, the fees for transactions on the crypto network and the speed of their execution does not depend on the distance over which the transfer needs to be made.
9. What is the essential qualification of an anti-money laundering officer?
    In addition to the ‘’standard set’’’(CAMS or other certification is usually a good basis for AML specialist, in-depth understanding of financial crime, ability to interpret legal acts, recommendations and other documentation), I would say that the ability to ‘’read criminals minds’’ is a useful skill as well, it means you could predict their steps and actions and to understand where you need to seek.
10. How has anti-money laundering changed over the time?
    I think numerous scandals and big cases lead to greater transparency and reveal lots of gaps in legislation. The opportunities in the field of AML are also changing swiftly. If we look back 30 years ago, there was no cryptocurrency, fast payments and e-wallets, but today a great amount of digital solutions are available to everyone today.
11. Do you have any recommendations to fintech startups about the AML process?
    Definitely, independent testing and ‘’sandbox’’ could help a lot to fintech startups about the AML questions.
12. If you trade with bitcoins, how do you manage to "explain" anti-laundering authorities the money-in & money-out?
    It is not allowed to trade with bitcoin if you are not registered as a subject of AML law in Baltic countries. The legislation in other countries may vary. In case such an entrepreneur is registered it means it is also supervised internally and externally.
13. How did you get CAMS certificate, how did you prepare the exam?
    I used ACAMS special manual and preparation cards. Also, my work experience helped to pass this exam, because lots of questions were related to the cases.
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