Aligning anti-money laundering, combating of financing of terror and financial inclusion : Questions to consider when FATF standards are clarified

Purpose – The purpose of this paper is to identify key questions that should be addressed to enable the Financial Action Task Force (FATF) to provide guidance regarding the alignment of anti-money laundering, combating of financing of terror and financial inclusion objectives.
Design/methodology/approach – The paper draws on relevant research and documents of the FATF to identify questions that are relevant to consider when it formulates guidance regarding the alignment between financial integrity and financial inclusion objectives.
Findings – The FATF advises that its risk-based approach enables countries and institutions to further financial inclusion. It is, however, not clear what the FATF means when its uses the terms “risk” and “low risk”. It is also unclear whether current proposals for financial inclusion regulatory models will necessarily limit money laundering (ML) aswell as terror financing risks to levels that can be described as “low”. The FATF will need to clarify its own thinking regarding low money laundering and low terror financing risk before it will be able to provide clear guidance to national regulators and financial institutions.
Originality/value – This paper was drafted to inform current FATF discussions regarding guidance on financial inclusion. The questions are relevant to all stakeholders in financial regulation.

Using fund transfer pricing for comparing financial performance among business units

This study aims to demonstrate by a simplified analysis how fund transfer pricing can be used to measure financial performance taking into account the flow of resources in a bank with only two branches. The present study was developed in three sections. The first section provides information regarding fund transfer pricing and its characteristics. This is followed by a section with an analysis demonstrating how fund transfer pricing can assist top management to evaluate financial performance in a financial institutions with only two business units. Finally, the third section has the concluding remarks about the benefits and limitations of the use of fund transfer pricing. This study uses a simple version of fund transfer pricing system to address a further complex problem which is the exchange of services among business units in a decentralized organization. The analysis has shown how fund transfer pricing can be used to manage a bank, directing the efforts of branch managers.

Regulating financial institutional culture: reforming the regulatory toolkit

Unethical behaviour and misconduct in the financial services industry is asignificant problem. Laws aimed at misconduct or incentives to misbehave can be rendered ineffective by poor culture within financial institutions. Various regulatory and industry initiatives to tackle the problem have been proposed or put in place in Australia. This article provides an overview of these initiatives and argues that while such strategies may be worthwhile, they also have shortcomings. The article contends that ameliorating cultural problems within the financial industry requires a multi-disciplinary approach and Australia should therefore consider introducing a supervisory technique pioneered by the Netherlands Central Bank (DNB) that incorporates social andorganisational psychology. It further argues that this approach, when placed in the hands of a regulator, offers a radical regulatory tool that could provide the “missing link” in promoting a culture of integrity within financial institutions.The DNB approach is described and various legal, theoretical and policy issues raised by this approach are discussed.