Financial Crimes Survey Presentation

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    Financial Crimes SurveyRe ort 2013

    Where is the exposure?

    Robert Nyamu

    Director, Deloitte Forensic Services East frica

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    Contents

    Overview

    Prevalence, modes and impact

    Financial crime prevention and

    AML regulatory frameworks acr

    2

    of financial crimes

    detection mechanisms

    oss East Africa

    2013. For information, contact Deloitte & Touche

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    Overview

    3

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    Respondents by Sector

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    The spread of respondents per sector

    was as follows: Banking sector 69%

    Insurance 25%

    Real Estate 3% and

    Capital Markets 3%

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    Asset Base of Respondents

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    63% of the respondents have an asset

    base of over US$ 3.5M10% have an asset base of betweenUS$ 1.2M and 3.5M

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    Domicile of respondents

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    The spread of respondents in the region

    was as follows: 38% are based in Kenya.

    22% are based in Uganda

    22% have a Regional Presence

    9% are based in Tanzania

    9% have a Global presence

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    Prevalence,mpac s ocrimes

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    odes and anc a

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    Prevalent forms of financial cri

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    The top three most prevalent forms of financial cri

    Cash theft at 72% in Kenya, 67% in Uganda an

    Cheque fraud at 44% in Kenya, 50% in Ugand

    Asset misappropriation at 33% in Kenya, 25% i

    e

    2013. For information, contact Deloitte & Touche

    e across East Africa are:

    d 71% in Tanzania.

    and 14% in Tanzania.

    n Uganda and 29% in Tanzania.

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    Common ways of perpetrating f

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    inancial crimes

    Across East Africa, perpetration of

    financial crimes commonly involvesa combination of internal andexternal parties.

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    Most likely to perpetrate interna

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    l financial crimes

    Across the region, most respondents

    indicated that non-management personnelwere most likely to perpetrate financialcrimes in the organisation.

    It is interesting to note that it is only in Kenyawhere senior management is considered

    likely to perpetrate financial crimes within theorganisation

    2013. For information, contact Deloitte & Touche

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    Likely causes of prevalence of f

    In Kenya, 57% of the respondentsfeel that the most likely cause offinancial crimes is the abundant

    liquidity in the industry which makes itattractive to fraudsters.

    In Uganda, 50% of the respondentsfeel that the most likely causes offinancial crimes are:

    Abundant liquidity in the industrywhich makes it attractive to

    Weak or inadequate financialcrimes controls; and

    Manipulation of data andcircumvention of IT controls.

    In Tanzania, 50% of the respondentsfeel that the most likely causes offinancial crimes are:

    Weak or inadequate financialcrimes controls; and

    Diversity of products which are

    not matched with robust controlsmechanisms.

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    inancial crimes

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    Prevalence, modes and impact

    Extent of threat posed by financial crimes

    When asked if financial crimes are posing a

    serious threat to the growth and expansion of theindustry, most of the respondents in the regionstated that it was a threat, but only to a smallextent

    Perceived extent of annual losses throughfinancial crimes

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    36% of respondents in Kenya and 25% ofrespondents in Tanzania stated that the industry islosing more than ten million US dollars as a resultfinancial crimes annually.

    In Uganda, 29% of therespondents stated thatthe industry is losingbetween one million andten million US dollars asa result of financial crimesannually

    of financial crimes

    2013. For information, contact Deloitte & Touche

    f

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    Perceived extent of annual loss

    19% of the respondents in the bankingsector feel that annual losses are likely to

    be above ten million dollars.

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    s in key sectors

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    In the insurance sector, 25% of therespondents feel that annual losses arelikely to be above ten million dollars

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    Impact of financial crimes

    Across the region, 100% of the respondents feel threputational damage.

    In Kenya, this is followed by actual financial loss atactual financial loss both at 50%.

    In Tanzania, 100% of the respondents also feel tha

    organizations.

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    t the greatest impact of financial crimes is

    71%, in Uganda by regulatory & legal risks and

    t actual financial loss has a great impact on their

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    Financial cripreven on anmechanisms

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    e e ec on

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    Financial crimes prevention me

    In all three countries, the majority of the respondenduties & job rotation as mechanisms to mitigate fin

    In Kenya, the second most commonly used mecha

    background checks on employees prior to recruitm

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    hanisms

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    s stated that they have implemented segregation of ncial crimes.

    ism to mitigate financial crimes is conducting of

    nt.

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    Financial crimes detection mec

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    anisms

    Across East Africa, most

    respondents conduct riskbased internal audits:

    100% in Kenya;

    83% in Uganda; and

    100% in Tanzania.

    Most organizations also

    2013. For information, contact Deloitte & Touche

    con uc r s asetransaction monitoring onan ongoing basis:

    71% in Kenya;

    67% in Uganda; and

    50% in Tanzania

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    Effectiveness of financial crime

    mechanisms

    Prevention

    Majority of the respondents stated that the

    financial crimes prevention mechanismswere effective in their organizations.

    However, a small minority in Kenya who feelthat the mechanisms in place were noteffective.

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    prevention and detection

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    Detection

    Majority of respondents stated that financial

    crimes detection mechanisms are effectivein their organizations. 17% of therespondents in Uganda and 21% of therespondents in Kenya stated that thefinancial crimes detection mechanisms inplace are very effective in their organizations

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    Financial crime prevention and

    Transaction monitoring systems

    Across the region, 67% of banks do not have

    and reporting of suspicious and cash transactsystem.

    None of the insurance companies have an aureporting of suspicious and cash transactionsthat they have virtually no cash transactions

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    detection mechanisms

    automated systems to facilitate monitoring

    ions, while 5% have a semi automated

    tomated system to facilitate monitoring and . Some of the insurance sector players stated

    2013. For information, contact Deloitte & Touche

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    Remediation measures

    Across the region, 86% of the banks stated th

    program to fill in gaps in customer due diligen88% of insurance companies stated that they

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    t they have a retrospective remediation

    e information for existing customers, while o not have such measures in place.

    2013. For information, contact Deloitte & Touche

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    Responsibility for dealing with

    organization

    The majority of the respondents in Kenya and

    and senior management are responsible for dorganizations.

    The majority of the respondents in Uganda stcompliance team as well as senior managemorganizations

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    inancial crimes in the

    Tanzania stated that the internal audit team

    ealing with financial crimes in their

    ted that it is the responsibility of the risk and nt to deal with financial crimes in their

    2013. For information, contact Deloitte & Touche

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    AML regulatoramewor s aAfrica

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    ry ross as

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    Perceived effectiveness of AML

    A majority of the respondents in Kenya and T

    framework is effective in combating financialUganda feel that the framework is not effectivdue to the lack of the necessary legislation.

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    regulatory framework

    anzania feel that the AML regulatory

    rimes. However, 83% of the respondents in e in combating these vices, which should be

    2013. For information, contact Deloitte & Touche

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    Perceived effectiveness of AML

    sectors

    67% of the respondents from the banking sec

    insurance sector stated that the AML regulatofinancial crimes.

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    regulatory framework for key

    tor and 50% of the respondents from the

    ry framework is effective in combating

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    Existence of AML compliance f

    Across the region, the majority of the orgAML compliance frameworks in place.

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    ameworks for key sectors

    nizations stated that they have

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    Components of AML complianc

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    e frameworks for key sectors

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