Strengthening AML/CFT and risk oversight: central bank strategies for dynamic challenges

All financial organizations currently face an exceptionally challenging external environment: increasing regulatory pressures, heavy reliance on external third-parties, dominance of cloud based services and Artificial Intelligence (AI), all amid makes issues related to Third Party Risk Management prominent for both regulators and organizations alike.

With a track record of successfully establishing a robust third party risk management (TPRM) function at the International Monetary Fund (IMF), Section Chief, Suyog Peshkar brings a unique perspective on the intersection of operational risks and outsourcing.

In his twenty plus years’ experience, Suyog has advised global firms as well as provided hands-on expertise in delivering outsourcing solutions to generate higher cost savings, mitigate risks and derive efficiencies. Suyog completed a LLM in Commercial and Corporate Law from the University of London and a Masters in Analysis, Design and Management of Information Systems from the London School of Economics (LSE), which enables him to provide ‘techno-legal’ advisory on complex issues related to sourcing governance, risk management and third party compliance.

Recognized as an operational and third party risk expert, Suyog is regularly invited to speak at industry conferences, risk panels and UN seminars. 

I am Eka Goglidze, professional specializing in Compliance for over 10 years, including 5 years’ experience in AML/CFT and also compliance with the international sanctions. My journey in these fields have been diverse, encompassing both private and public sectors. 

Over the last five years, I have gained a comprehensive experience in AML/CFT. I was engaged in onsite inspections of the commercial banks for several years, and contributing to legislative developments in this field. In addition, I played a crucial role in the introduction of a robust supervisory/regulatory system for Virtual Asset Service Providers (VASPs). 

During my career at the public sector, I was permanently involved in international collaboration, managing technical assistance programs and fostering communication with diverse stakeholders, including financial sector representatives and public officials from various countries.

A career highlight? A highlight of my career was establishing, managing and guiding the division responsible for the regulatory/supervisory framework of VASPs, as well as supervision of International Sanctions compliance. This role has been challenging, but resulted in significant progress for my division, positioning it as an important player worldwide in AML/CFT supervision of VASPs. It also contributed to our country achieving remarkable results in international sanctions compliance within the region.

My compliance experience spans almost 20 years. My career progression in supervision was greatly influenced by my experience in the private banking sector. Approaching processes from a business standpoint enabled me to maintain a balanced approach as a supervisor.

Notable project I spearheaded was the implementation of off-site supervision for financial sector in 2015. Together with my team I developed a risk matrix to gather sector information and assign risk, facilitating the effective determination of risk-based supervisory measures. Our off-site risk assessment model has been adopted by several countries, including those in Europe, to enhance the efficiency of their supervisory processes.

In 2020, Moneyval (Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism) evaluated Georgia's compliance with FATF 40 Recommendations. This involved extensive work, such as updating guidance documents for financial institutions, establishing a new supervisory framework, and conducting sector training. I led this entire process, which resulted in a positive evaluation of the National Bank of Georgia. Subsequently, I was chosen as an evaluator for Moneyval. As a result, in 2022, I participated in evaluating Romania's AML/CFT system in terms of preventing money laundering and countering the financing of terrorism which I think was a great experience.

Since January 2023, I serve as the Head of the AML Department and play an active role in implementing the VASPs supervisory framework and ensuring international sanctions compliance. The supervisory measures carried out together with my team significantly contributed to receiving positive responses from international partners, positioning our country as a regional leader in both areas.

ROSS DELSTON is an independent American attorney, expert witness, and former banking regulator (FDIC) who has specialized in AML/CFT issues since July 2000. Ross has participated in the monitorships of AIG and BNP Paribas, and has been named as an expert witness on AML issues in 23 civil and criminal cases in the US and Canada. Ross has also  been a consultant to the IMF on AML/CFT and banking matters since 1997 and has participated in nine AML/CFT assessments of offshore financial centres, including Jersey, Bermuda, and St. Vincent and the Grenadines. In that role, he has drafted laws for numerous countries and has trained government officials and commercial bankers in Africa, Asia, Eastern Europe and the former Soviet Union. Additionally, he was a consultant to the World Bank from 1998 – 2014 on banking regulation, resolution, and insolvency issues. Ross is a frequent lecturer on AML/CFT and banking topics, including presentations at the IMF, the Reserve Bank of India, and the Peoples Bank of China, and has been quoted in the New York Times, Times of London, Washington Post, Wall Street Journal, and Reuters.

An economic and financial professional with over ten(10) years’ experience, working in varied capacities with the central bank of Ghana in the areas of AML/CFT&P, Consumer Protection, Fintech and Non-Bank Financial.