发挥反洗钱监管走访的“诊断”作用

Making the best of regulatory visits in"diagnosing"AML flaws

我国反洗钱工作不断向纵深推进,“风险为本”的反洗钱工作理念不断深化,正处于从“规则为本”向“风险为本”转型爬坡过坎的关键阶段,函待构建差异化、可预期、持续性的监管机制。如何充分发挥监管走访“短、平、快”的特点,及时“诊断”出金融机构反洗钱控制措施存在的重大缺陷,值得花力气探索和研究。

As China is making in-depth progress in AML,the risk-based AML work concept continues to gain awareness.We are at a critical transitional point from"rules-based"to"risk-based"pattern,desperately lacking a regulatory mechanism that's differentiated,predictable and sustainable.However,it is difficult to maintain the continuity of AML supervision by relying solely on on-site inspections,which feature limited supervisory resources and"rigid"requirements.In addition,excessive or long-term reliance on on-site inspections may also shed its authority.The author points out that we should make the best of flexibility and rapidness of regulatory visits to"diagnose"major flaws in AML measures of financial institutions in a timely manner.