"Providing results-driven solutions to private corporations, regional entities, and to multilateral and national institutions holding public policy mandates"

The sophisticated inter-workings of global and domestic money laundering schemes--together with terrorist financing--threaten the stability of the international system, enable crime, fuel corruption, and erode confidence in the rule of law.  Due to the global nature of financial and communications networks, no institution or government alone can have a sustained impact in the absence of concerted capacity building efforts and effective coordination across borders.  Hence, Sharakpur's emphasis on ensuring compliance with the rules and standards established by the national/global regulatory agencies.

 AML/CFT Services--An Example

Sharakpur’s approach to anti-money laundering (AML) and Combating the Financing of Terrorism (CFT) is to advise its clients to proceed on a step-by-step basis.  The firm believes that this creates clarity and fosters a cost-efficient process with greater client satisfaction.  In so doing, it adopts the following four independent phases: (a) evaluation/needs assessment, followed by client-approved segments for: (b) design and implementation; (c) training; and (d) monitoring.  The four phases are:

- Phase 1—Evaluation/Needs Assessment

The evaluation provides a benchmark to determine the adequacy of existing programs in comparison with national and international best practices.  A review will include: existing laws, regulations, policies, practices, enforcement, organization, internal controls, training, information management, and budget resources.  The existing regime will be evaluated against FATF 40+9 recommendations of the Financial Action Task Force (FATF) 40 recommendations as well as inter-relationship with the USA Patriot Act and other laws.  Areas of improvement will be identified.  In the case of private associations, the evaluation will consider the feasibility of model programs and systems which may be shared by member institution in order to obtain the benefits of scale.  This may include concepts for shared facilities on a cost-effective basis.  Depending on the circumstances, a Phase 1 Evaluation could involve a team of five to 10 professionals and could require 30 to 50 person-days.  In each case, a work plan and budget would be tailored to the Client’s requirements.  The project would commence with a review of relevant documents, but most of the activity would be at the Client’s site in examination of existing programs and in consultation with key personnel.

- Phase 2—Design and Implementation approved by the Client

This Phase would be focused on implementing any recommendations derived from the Phase 1 evaluation.  The Phase 1 assessment will vary in each case and the need for further services, if any, must be tailored to the particular circumstances.  Moreover, the Client may assign priorities and proceed with any implementation in selected segments.  The purpose is to assure flexibility so that the Client may coordinate any work plan with its regular activities, while recognizing the importance of AML/CFT programs.  Phase 2 may involve establishing or amending laws, regulations, policies, procedures, and internal controls; installing or enhancing robust information technology; establishing or improving enforcement and compliance programs; and developing appropriate manuals and documentation.

- Phase 3—Training approved by the Client

For regulators or supervisors of financial institutions, the training Phase would offer two main components: (a) training of internal management and personnel; and (b) establishing training programs for regulated institutions, which might be either mandatory or voluntary. Experience shows that training must be an on-going process, so the Phase 3 plan should include the development of systems for continuous education and training. Using modern technology, initial and continuing training programs could be established using “distant learning” techniques.  While Phase 3 is a discrete component, training activities could overlap with Phase 2.  As various implementation projects are underway, some training could commence in order to have fully-qualified personnel ready to administer the enhanced programs.

- Phase 4—Monitoring approved by the Client