Basic Principles of the International Compliance Council’s Work
Purpose of the initiative
1. The International Compliance Council (hereinafter – ICC) is established to enhance opportunities for dialogue with the private sector.
2. Since 2006 the EAG has been holding consultations with private sector institutions of the region (credit and other financial and non-financial institutions carrying out transactions with funds) on the practical application of the FATF international AML/CFT standards. Since 2014, the annual International Supervision Workshop, which includes consultations with the private sector, has been organised under the auspices of EAG.
3. Based on the events’ outcomes, materials are formed on the basis of speeches, presentations and ideas that contribute to a deeper understanding of the FATF Standards, identification of common risks and threats, as well as their mitigation based on best experience and practices.
4. The similar arrangement was established in October 2007 pursuant to the decision of the Plenary of the Financial Action Task Force (FATF)2 that holds annually the Consultative Forum, made up of representatives of international organizations, major financial institutions and DNFBPs of the FATF member states. The Forum facilitates a direct engagement between the FATF, its members and the private sector on AML/CFT issues.
5. On 26-27 September 2019, Kazan (Russia) hosted the 5th International EAG/ITMCFM workshop “Public-Private Partnership as a Tool to Improve AML/CFT Efforts and Consultations with the Private Sector”. Participants underscored the importance of sharing experiences in improving cooperation between supervisors and the private sector, facilitating feedback to improve the quality of suspicious transaction reporting, and developing new approaches to the detection of customer activities in high-risk areas.
6. The workshop ended with a petition to the EAG Plenary to consider the possibility of establishing an ICC under the auspices of the EAG, responsible for the following:
- exchange of experience and best practices on the application of AML/CFT preventive measures by financial institutions and DNFBPs;
- information interaction of private sector representatives with supervisory authorities and FIUs of the EAG countries, including in order to provide feedback and increase the level of private sector’s involvement in mitigating existing risks, identifying new risks and developing typologies;
- organization of interaction between representatives of the expert and professional community in the AML/CFT field in order to identify strategic issues, research topics and projects for consideration within the framework of the ICC events.
Organization of ICC work
7. The EAG Strategy 2019-2023 provides for the involvement of representatives of the private sector in EAG activities as a way to promote effective cooperation at the regional level.
8. The establishment of the ICC will promote the continuity of public-private partnership mechanisms in the EAG space and enhance participation of the private sector’s stakeholders.
9. The ICC will be vested with advisory functions only.
10. The ICC events are included in the EAG annual plan, approved by the Plenary meeting.
11. Based on the proposals of the EAG member states, the ICC events can also be held in agreement with the EAG Chairman, taking into account the initiating state’s available resources for their organization.
12. The preparation of the ICC events is carried out by the Contact Group, which includes representatives of the competent authorities (first of all, FIUs and supervisory authorities), private sector’s representatives upon submission by the member states’ delegations, representatives of the EAG Secretariat, as well as the ITMCFM. The specific composition of the participants is determined depending on the event’s agenda and on the basis of the available (approved) list of the Contact Group.
13. General coordination of the ICC will be carried out by the EAG Secretariat with the organizational and technical support of the ITMCFM.
14. The results of the ICC events are reported to the EAG Plenary meeting.
15. The ICC initiatives supported by the EAG Plenary meeting can be included for consideration in the EAG working groups’ agendas.