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By Pierre-Laurent Chatain, Raul Hernandez-Coss, Kamil Borowik, Andrew Zerzan

Integrity in Mobil cell monetary prone explores thoughts to spot and deal with capability funds laundering and terrorist financing dangers in cellular monetary providers. The paper presents counsel at the top technique of assessing perceived as opposed to genuine dangers and identifies particular measures to mitigate the particular hazards.

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Extra resources for Integrity in Mobile Phone Financial Services: Measures for Mitigating the Risks of Money Laundering and Terrorist Financing (World Bank Working Papers)

Sample text

75. Maxis. qxd 5/20/08 38 9:19 AM Page 38 World Bank Working Paper general public. For the industry, robust internal surveillance mechanisms are critical to protecting their business and reputation, and to building confidence among customers. Likewise, FATF Recommendation 15 clearly requires financial institutions (banks and non-banks) to develop AML and CFT programs (FATF 2003). These programs should include, among others, internal policies, procedures, and controls, including appropriate compliance management arrangements and an audit function to test the system.

Qxd 5/20/08 9:19 AM Page 15 Integrity in Mobile Phone Financial Services 15 threaten economic development. 32 AML and CFT regulations that do not recognize local conditions may hinder efforts to expand financial access (Isern and others 2005). Regulations that ignore the often stark differences in market environment and institutional capacity within and between countries could make for an inefficient preventive regime. Recent evidence (Bester and others, Forthcoming) suggests that such obstacles are fully avoidable granted that policymakers modify their specifications according to local necessity in order to be realistic, flexible, and driven by a risk-based analysis in their approach to AML and CFT regulations.

53. The Committee of Sponsoring Organizations of the Treadway Commission (COSO) developed a model for evaluating internal controls in 1992 that has been adopted as the generally accepted framework for internal control. It is widely recognized as the definitive standard against which organizations measure the effectiveness of their systems of internal control. qxd 5/20/08 9:19 AM Page 33 CHAPTER 4 Applying FATF Recommendations to m-FS hile the previous chapter addressed the observed and perceived risks of the m-FS categories, this chapter covers the extent to which the mitigation practices observed are actually consistent with the international AML and CFT standards.

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