The recent pandemic has changed the way we conduct business throughout the world, and the Compliance sector has been no less affected in the manner it has had to carry out its mandated tasks. This sector had to quickly adapt to working remotely as the massive shutdowns required adjusting the compliance program to still be effective and efficient even in the midst of the pandemic. Most of its business activities were forced to be conducted virtually using online platforms such as Zoom and Microsoft Teams. Therefore, there was a shift from face to face training and meetings to virtual sessions. Furthermore, compliance training, reporting and assessments were adjusted in the new environment. Some areas were able to adjust better than others, for example, customer onboarding. Although these shifts and adjustments have occurred it is just as effective because the regulatory framework and policies/procedures for companies are still being reviewed, amended and implemented on an ongoing basis.

COVID-19 has led to a level of ingenuity and flexibility amongst organizations inclusive of Compliance facilities (FIU, FSC) where they are no longer subjected to a “brick and mortar” and a stringent 8:30am to 4:30pm work schedule, but the utilising of internet facilities to complete work responsibilities and a greater sense of autonomy between employees. In addition, it is evident that an ever-evolving business environment with high expectations for seamless, timely and responsive services by customers has put pressure on financial institutions and many other businesses to be more technology-driven and allow for easy access to customer responses and demands. The COVID-19 pandemic has only exacerbated these demands. In order for these service expectations to be met, the current systems and processes used by the compliance functions will have to be equally robust to adjust to the new products and services. What has been realized in this restricted business environment is that our AML tools and processes must be just as responsive not only regulatory and business changes and consumer needs but also to crisis implications as well.

The Coronavirus has threatened many economies around the world and the words recession and depression were being discussed especially at the governmental and business level. Economic trends are of high importance to the Compliance Sector because these trends can determine the anticipated level of Money Laundering and Terrorist Financing that can threaten financial institutions. The current trend of depressed markets can enhance such criminal activities because a level of desperation can set in amongst Insurance, Private Banking and Trust companies just to name a few, who are regularly compensated through commission and pressured to maintain a high-net worth of clients in their business portfolio. Therefore, the MLO should consistently analyze the company’s customer due diligence procedures before the onset of a transaction and heighten their KYC policies. Additionally, training of all employees should be conducted at this time highlighting the sanctions that can be imposed for breaking any of the regulatory framework and for the “tipping off” of clients.

The pandemic has created a new norm of wearing of masks, sanitizing and the practice of social distancing but the norm for all financial institutions should be to regularly conduct audits on their CDD, KYC processes, maintain integrity and follow the guidelines implemented by the FATF, FSC and other regulatory bodies.