ABA ROLI is a non-profit organization that implements legal reform programs in roughly 50 countries around the world. ABA ROLI has nearly 500 professional staff working abroad and in its Washington, D.C. office. ABA ROLI’s host country partners include judges, lawyers, bar associations, law schools, court administrators, legislatures, ministries of justice, and a wide array of civil society organizations, including human rights groups.
The American Bar Association Rule of Law Initiative (ABA ROLI) is seeking 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 to develop “consultation briefs” on emerging money laundering threats in South Asia and the roles and responsibilities of AML/CFT regulators, supervisors, and private sector compliance officers in preventing and responding to emerging money laundering threats.
BACKGROUND
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 raise awareness of the risk-based approach and identify and discuss emerging ML/TF threats, ABA ROLI and its local partners in South Asia will convene financial institutions and designated non-financial businesses and professions with their supervisors and regulators through country-level Compliance Forums and a virtual South Asia Regional Conference on Emerging Money Laundering Threats.
ABA ROLI will convene Compliance Forum meetings in two countries. To familiarize Compliance Forum members with the risk-based approach and raise awareness of AML/CFT compliance requirements, ABA ROLI and its local partner organizations will prepare a series of sector-specific consultation briefs for Compliance Forum members elaborating on the roles and responsibilities of each sector’s regulators and supervisors, as well of those of the regulated FIs or DNFBPs.
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 prepare a series of sector-specific consultation briefs for Compliance Forum members in two countries. Consultation briefs will elaborate on the roles and responsibilities of each sector’s regulators and supervisors, as well as those of the regulated FIs or DNFBPs. ABA ROLI tentatively anticipates developing a total of eight (8) consultation briefs for banks, non-bank financial institutions, accountants, lawyers, precious metals and gems dealers, and/or real estate agents in two countries (four (4) consultation briefs per country).
Likewise, to raise awareness of regional ML threats among South Asian supervisors, regulators, FIs, and DNFBPs and facilitate information and knowledge sharing, ABA ROLI will convene a virtual conference on emerging ML/TF threats in South Asia. The International Consultants will each lead one or more sessions during the virtual conference to provide training on a risk-based approach, identifying and responding to ML/TF threats, and emerging threats in the South Asia region. The conference will include sector- and threat-specific breakout sessions.
DURATION AND SCOPE OF WORK
The International Consultants will each spend roughly ten (10) to twenty (20) working days over a maximum of three months, beginning in January or February 2021, supporting ABA ROLI and its local partners by:
● Conducting research on emerging money laundering threats in South Asia and the roles and responsibilities of AML/CFT regulators and supervisors within the target countries.
● Mapping money laundering threats within assigned sectors.
● Identifying sector-specific compliance challenges.
● Participating in conference calls with ABA ROLI staff, volunteers, and/or local partner organizations to discuss and manage the brief development process.
● Drafting sector-specific consultation briefs or portions thereof independently or together with ABA ROLI or local partner staff or volunteers.
● Reviewing and commenting on consultation briefs developed by other members of the research and drafting team, including briefs drafted by ABA ROLI’s local staff and/or local partner organizations.
● Proofreading and/or cite checking consultation briefs.
● Preparing and delivering presentations for the virtual South Asia Regional Conference on Emerging Money Laundering Threats.
● Any other related task as directed by ABA ROLI.
REQUIRED QUALIFICATIONS
● 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.
● 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
Home-based
REPORTING LINES
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.
CONTACT
Interested candidates should send a resume and cover letter to alexandria.farris@americanbar.org with the subject line “International Consultant – Stop ML”. The closing date is December 30, 2020. Applications will be considered as they are received, and the position may be filled before the closing date.
How to apply:
Interested candidates should send a resume and cover letter to alexandria.farris@americanbar.org with the subject line “International Consultant – Stop ML”. The closing date is December 30, 2020. Applications will be considered as they are received, and the position may be filled before the closing date.