Existing customers As I have already mentioned, it is likely that AIs will have to upgrade their due diligence procedures in some respects to comply with changing international standards. Obviously, these enhanced procedures would be applied to new banking relationships. But this begs the question about what should be done in relation to existing customers. To what extent should institutions go back and undertake renewed verification of the identity of existing customers? Our current view is that we should not impose an across the board requirement in this respect, but it would certainly be sensible to review those existing customers who fall into higher risk categories. The six major banks in the UK have just announced that they will undertake a risk-based initiative of this type. I would encourage those AIs with a large customer base to do the same. Other triggers for review of existing records may arise when a customer undertakes a significant transaction and where there is a material change in account operation or customer documentation standards. The way forward These are some, but by no means all, of the current issues we are considering in the context of our revised guideline. We hope to have something ready for consultation with the industry later in the year. While this may impose new obligations on AIs, we will try to ensure that these are of a nature that wellmanaged institutions would adopt of their own accord.
David Carse: Anti-money laundering and the role of supervision Speech by Mr David Carse, Deputy Chief Executive of the Hong Kong Monetary Authority, at the Hong Kong Institute of Bankers, Hong Kong, 23 August 2002. *  *  *  Ladies and Gentlemen,  Introduction I welcome the opportunity to talk to the Institute on the subject of the fight against money laundering and the role that supervision plays in this. This is a good time to speak on this subject since we are currently reviewing our 1997 anti-money laundering guideline in the light of the latest developments in this area. I will use this speech to highlight some of the issues that we are addressing. It is also a useful occasion for me to remind the bankers gathered here today how important it is to combat money laundering. This should really go without saying and I do not intend to dwell on it too much. The key message is that authorized institutions (“AIs”) should view anti-money laundering systems as an essential means of self-preservation - and not as a nuisance or an unnecessary expense that is imposed upon them. The events of 9/11 have heightened the international concern about money laundering. There is less and less patience with jurisdictions, and their banks, that do not comply with the international standards laid down by bodies like the Financial Action Task Force (“FATF”). The FATF has begun to “name and shame” jurisdictions that it regards as non-cooperative countries and territories (“NCCTs”) in tackling money laundering.