The American Bar Association Rule of Law Initiative (ABA ROLI) seeks two or more home-based consultants with expertise in anti-money laundering regulation and compliance for its new South Asia Transnational Partnerships against Money Laundering (Stop ML) program. The selected consultants will help ABA ROLI and its local partners in South Asia to develop how-to manuals, process maps, and/or templates for use by South Asian anti-money laundering/countering financing of terrorism (AML/CFT) regulators in issuing notices/advisories on emerging money laundering threats to the private sector.
Predicate offenses to money laundering, including drug trafficking, trafficking in persons, human smuggling, and organized crime, corruption, and bribery, as well as terrorism, are endemic across South Asia. Financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) in the region, however, do not effectively implement anti-money laundering/counter financing of terrorism (AML/CFT) preventive measures commensurate with their money laundering risks and often fail to detect and report suspicious activities and transactions linked to money laundering or terrorist financing (ML/TF). Without these reports, financial intelligence units (FIUs) are unable to detect and refer ML/TF cases to relevant authorities for investigation and legal action. FIs and DNFBPs must work together with public sector supervisors and regulators to increase their awareness of emerging money laundering threats and build the capacity to detect and file actionable reports.
To address these challenges, ABA ROLI launched the South Asia Transnational Partnerships against Money Laundering (Stop ML) program in September 2020 to build partnerships between South Asian public sector supervisors and regulators and private sector FIs and DNFBPs to employ a risk-based approach to identify emerging money laundering threats, improve detection of suspicious activities and transactions, and file actionable suspicious transaction reports with FIUs. The Stop ML program will strengthen public and private sector understanding of AML/CFT compliance requirements, implementation of a risk-based approach, and emerging ML threats, and lead to increased effectiveness on Financial Action Task Force (FATF) Immediate Outcomes IO3 and IO4. Increased suspicious activity reporting will enable FIUs to detect and refer money laundering cases to relevant authorities for legal action, which along with enhanced preventive measures within FIs and DNFBPs, will deny criminal groups access to funds to carry out and profit from transnational crime.
ROLES AND RESPONSIBILITIES
To support South Asian AML/CFT regulators to develop notices/advisories to the private sector about emerging ML trends, ABA ROLI will support its local partners in South Asia to develop how-to manuals, process maps, and templates to guide regulators through the process of developing and issuing notices/advisories to their regulated entities. The how-to manuals will provide step-by-step guidance for regulators on issuing notices/advisories, with special focus on a risk-based approach and notifying regulated entities about emerging trends in ML/TF. The notice/advisory templates are expected to simplify the process of issuing advisories and increase the likelihood that regulators will do so.
The International Consultants will work independently and/or with ABA ROLI’s local staff, partner organizations in South Asia, and/or pro bono experts to undertake one or more of the following tasks:
· Develop sector-specific how-to manuals for regulators on the issuance of notices/advisories;
· Support South Asian AML/CFT regulators to develop sector-specific notice/advisory templates;
· Develop process maps for issuing notices/advisories, tailored to specific regulators;
· Develop training materials and lead (virtually) a workshop for regulators on developing and issuing notices/advisories, including an orientation to the use of process maps and templates;
· Share sample advisories/notices from other jurisdictions; and/or
· Answer questions from regulators.
DURATION AND SCOPE OF WORK
Depending upon the number of International Consultants and pro bono volunteers recruited and the specific tasks assigned, each incumbent is expected to spend approximately five (5) to fifteen (15) working days supporting the program during 2021, with the bulk of the work to be accomplished between February and August. Consultants will each support ABA ROLI and its local partners by performing one or more of the following functions:
· Conducting research on emerging money laundering threats in South Asia, the roles and responsibilities of AML/CFT regulators and supervisors within the target countries, and current experience and processes for issuing notices/advisories to the private sector;
· Drafting sector-specific how-to manuals for regulators on their overall regulatory function with special focus on RBA and notifying regulated entities about emerging trends in ML/TF through the issuance of advisories/notices;
· Creating or guiding local partners to create notice/advisory templates and process maps to assist AML/CFT regulators in developing and issuing notices/advisories to their regulated entities;
· Compiling AML/CFT advisories from other parts of the world that can be provided as examples to South Asian regulators;
· Designing and delivering a one-day training workshop for regulators on developing and issuing notices/advisories, including an orientation to the use of process maps and templates;
· Reviewing and commenting on how-to manuals, templates, or process maps developed by other members of the research and drafting team, including materials drafted by ABA ROLI’s local staff and/or local partner organizations;
· Answering questions from regulators;
· Participating in conference calls with ABA ROLI staff, volunteers, and/or local partner organizations to discuss and manage assigned activities; and/or
· Any other related task as directed by ABA ROLI.
● University degree in law, business, accounting, economics, finance, international relations, or another relevant field. An advanced degree would be an advantage.
● At least seven (7) years of professional experience in law, banking, compliance, regulation, or another relevant field. Prior experience with the risk-based approach; suspicious activity reporting; regulation and supervision of banks, non-bank financial institutions, or designated non-financial businesses and professions; and/or in private sector AML compliance is required. Prior experience developing AML/CFT notices/advisories on behalf of an AML regulator or an FIU would be a strong advantage.
● Understanding of international anti-money laundering frameworks, particularly the Financial Action Task Force Recommendations and Methodology. Knowledge of money laundering and/or terrorism financing threats and challenges in South Asia and experience in the region is preferred.
● Prior experience with international capacity building programs is strongly preferred.
● Excellent research skills.
● Fluency and strong written communication skills in English are required. Knowledge of Dhivehi, Urdu and/or Pashto would be an advantage.
PLACE OF PERFORMANCE
International Consultants will report to either the ABA ROLI Senior Technical Advisor in Washington, D.C. or ABA ROLI’s Program Manager – Anti-Money Laundering in the Maldives,
Qualified candidates should send a resume and cover letter to firstname.lastname@example.org with the subject line “International Consultant – Stop ML”. The closing date is January 25, 2021. Applications will be considered as they are received, and the position may be filled before the closing date.