- President, Clement Advisory Group - AML Services
- Officer-in-Charge, Proceeds of Crime, Royal Canadian Mounted Police
- Managing Director, IPSA International, Toronto
- Operations Officer, Executive Diplomatic Protection, assigned to Canadian President Chretien
- Foreign Service Liason Officer, Hong Kong
- Garry’s 1996 undercover operation into tobacco smuggling from the US into Canada which resulted in the highest civil penalty against the cigarette companies in Canadian History
- All 7 Best Practices
- Pre-Meeting Discovery Process
- One-on-One Call with Expert
- Meeting Summary Report
- Post-Meeting Engagement
Anti-Money Laundering - Banks - Canada
- More prescriptive regulation is likely due to the financial industry’s inability to address potential AML issues through a flexible risk model.
Recent events such HSBC's $1.9 billion money-laundering settlement highlight that regulators are expecting organizations to implement measures to thwart criminals. The result is legislation to clamp down on tax cheats, foreign corrupt practices and various money laundering activities. Organizations will continue to be required to demonstrate they have sufficient expert resources to effectively uphold regulations and the ability to identify various terrorist or criminal trends.
- The financial community continues to fail at being proactive in preventing their organisations from being used by criminals to launder illicit revenues.
Recent cases (HSBC, BMO, Standard Chartered) demonstrate that the financial community has still not achieved an optimum level of compliance and that the weaknesses within their organizations have been exploited. Senior management and boards must set a new standard and put ethics above profit.
- Organizations have unwittingly and, in some cases wittingly, been involved in dealing with corrupt foreign regimes and paying foreign officials in order to secure contracts.
Many countries have implemented laws to make bribery and payoffs illegal. Although we often view corruption to be the domain of developing nations, many developed nations, including Canada and the U.S., have been shown to be part of the problem.
We need to have senior managers who demand that all large business transactions be assessed from a risk potential. It will take brave managers to risk losing contracts in developing countries, since the playing field has yet to be leveled. But only through ethical leadership can corruption be thwarted.
- Organizations are paying severe financial penalties for failing to take reasonable measures to prevent being used by criminal groups or sanctioned regimes.
The trend to larger and larger regulatory penalties will continue and the next trend will be the criminal charging of senior managers and boards of directors who do not ensure their organization has the ability to achieve compliance.