我国商业银行反洗钱合规管理现状分析
发布时间：2018-11-09 11:31
【摘要】：随着全球经济一体化、金融国际化进程加速,洗钱行为特别是恐怖融资对社会的危害日益显著。洗钱活动为恐怖主义分子、贩毒者、贪污官员以及其他经济犯罪活动提供了经济基础,影响了社会稳定,并对国家的安全带来了威胁,进而损害国家经济秩序,危害金融机构的信誉。20世纪90年代以来,全球相继发生的金融机构重大操作风险案件和洗钱案件等违规事件,使各国的监管层越来越意识到加强金融机构内部反洗钱合规管理的重要性和紧迫性,并因此陆续制定了有关反洗钱合规管理方面的文件。近一段时间以来,反洗钱合规管理作为一种风险控制手段,逐渐引起了世界范围内银行业的重视和关注。在完善商业银行反洗钱控制体系建设、及时预防洗钱交易行为、提高自我风险抵抗能力等方面,已是商业银行反洗钱合规管理的中心工作。在我国反洗钱工作起步较晚的背景下,如何倡导商业银行建设符合自身特点的反洗钱内控合规文化,形成有效的反冼钱合规管理体系,已成为我国商业银行迫切需要研究和解决的课题。 目前,我国商业银行以“风险为本”的风险管理理念为指引,依据相关的反洗钱法律法规,逐步建立起了反洗钱组织机构和工作制度,基本满足了监管机构的监管要求,反洗钱合规管理已经成为商业银行合规风险管理和内部控制的重要组成部分。但与国外银行多年来的实践相比,我国商业银行的反洗钱合规管理还存在很多差距,具体表现为：一是反洗钱组织机构建设与反洗钱发展要求不匹配、反洗钱工作人员匮乏、制约了内控制度的落实；二是风险识别手段单一,在洗钱风险识别计量和评估方面的研究和经验还较少,风险监测和风险控制能力较弱；三是内部控制制度尚需完善,反洗钱部门与业务部门的横向协作机制薄弱,影响了反洗钱工作成效；四是合规风险管理理论应用在反洗钱风险控制实务中还存在诸多不足。 对商业银行反洗钱合规管理优化策略的研究,丰富和完善了反洗钱合规管理理论,为商业银行改进反洗钱合规管理工作提供了借鉴。一方面,通过建立反洗钱管理措施相互融合的机制,奠定协调机制、共享机制的基础上,将反洗钱业务操作纳入集中处理,解决反洗钱制度执行力弱、管理链条长的问题,有利于反洗钱管理部门对反洗钱工作的管理控制,提高了管理效率,增强了执行力；另一方面,提出了优化反洗钱管理体系的建议,并提出适用于商业银行反洗钱合规管理的工作重点,如对业务部门反洗钱行为进行风险提示、风险评估,加强监测信息共享等风险监测手段,丰富了风险监测的方法,对提高商业银行反洗钱管理成效具有重要意义。
[Abstract]:With the integration of global economy and the acceleration of the process of financial internationalization, money laundering, especially terrorist financing, has become more and more harmful to the society. Money laundering provides an economic base for terrorists, drug traffickers, corrupt officials and other economic criminal activities, affects social stability and threatens the security of the country, thereby undermining the economic order of the country, Endangering the credibility of financial institutions. Since the 1990s, major operational risk cases and money laundering cases of financial institutions have occurred in succession around the world. The regulators of various countries have become more and more aware of the importance and urgency of strengthening the compliance management of anti-money laundering within financial institutions, and as a result, documents on anti-money laundering compliance management have been developed one after another. In recent years, anti-money laundering compliance management, as a means of risk control, has gradually attracted the attention of the banking industry around the world. In the aspects of perfecting the anti-money laundering control system of commercial banks, preventing the money laundering transactions in time, and improving the ability of self-risk resistance, it has been the central work of the compliance management of anti-money laundering in commercial banks. Against the background of the late start of anti-money laundering in our country, how to advocate the commercial banks to build the internal control and compliance culture of anti-money laundering in accordance with their own characteristics, and to form an effective anti-laundering compliance management system. Commercial banks in China have become an urgent need to study and solve the problem. At present, under the guidance of the risk-based risk management concept and in accordance with the relevant anti-money laundering laws and regulations, Chinese commercial banks have gradually established an anti-money laundering organization and work system, which basically meets the regulatory requirements of the regulatory body. Anti-money-laundering compliance management has become an important part of compliance risk management and internal control of commercial banks. However, compared with the practice of foreign banks over the years, there are still many gaps in anti-money laundering compliance management of commercial banks in our country. The specific manifestations are as follows: first, the construction of anti-money laundering organizations and the development requirements of anti-money laundering do not match the requirements of the development of anti-money laundering, and the staff of anti-money laundering are scarce. Restricted the implementation of internal control system; Second, the risk identification method is single, the research and experience in money laundering risk identification measurement and evaluation is still less, and the ability of risk monitoring and risk control is relatively weak; Third, the internal control system needs to be improved, and the horizontal cooperation mechanism between anti-money laundering departments and business departments is weak, which affects the effectiveness of anti-money laundering; fourth, compliance risk management theory in anti-money-laundering risk control practice still has many shortcomings. The research on the optimization strategy of anti-money laundering compliance management of commercial banks enriches and perfects the anti-money laundering compliance management theory and provides a reference for commercial banks to improve the anti-money laundering compliance management. On the one hand, on the basis of establishing a mechanism of mutual integration of anti-money laundering management measures, establishing a coordination mechanism and sharing mechanisms, the operation of anti-money laundering is brought into centralized processing, so as to solve the problem of weak execution of anti-money laundering system and long management chain. It is beneficial to the management and control of anti-money laundering work by the administrative department of anti-money laundering, improves the management efficiency and strengthens the executive power; On the other hand, it puts forward some suggestions to optimize the anti-money laundering management system, and puts forward the key points for commercial banks' anti-money laundering compliance management, such as risk warning and risk assessment for anti-money laundering in business departments. Strengthening the risk monitoring means such as information sharing enriches the methods of risk monitoring and is of great significance to improve the effectiveness of anti-money laundering management of commercial banks.
【学位授予单位】：山东大学
【学位级别】：硕士
【学位授予年份】：2014
【分类号】：F832.2
本文编号：2320282
[Abstract]:With the integration of global economy and the acceleration of the process of financial internationalization, money laundering, especially terrorist financing, has become more and more harmful to the society. Money laundering provides an economic base for terrorists, drug traffickers, corrupt officials and other economic criminal activities, affects social stability and threatens the security of the country, thereby undermining the economic order of the country, Endangering the credibility of financial institutions. Since the 1990s, major operational risk cases and money laundering cases of financial institutions have occurred in succession around the world. The regulators of various countries have become more and more aware of the importance and urgency of strengthening the compliance management of anti-money laundering within financial institutions, and as a result, documents on anti-money laundering compliance management have been developed one after another. In recent years, anti-money laundering compliance management, as a means of risk control, has gradually attracted the attention of the banking industry around the world. In the aspects of perfecting the anti-money laundering control system of commercial banks, preventing the money laundering transactions in time, and improving the ability of self-risk resistance, it has been the central work of the compliance management of anti-money laundering in commercial banks. Against the background of the late start of anti-money laundering in our country, how to advocate the commercial banks to build the internal control and compliance culture of anti-money laundering in accordance with their own characteristics, and to form an effective anti-laundering compliance management system. Commercial banks in China have become an urgent need to study and solve the problem. At present, under the guidance of the risk-based risk management concept and in accordance with the relevant anti-money laundering laws and regulations, Chinese commercial banks have gradually established an anti-money laundering organization and work system, which basically meets the regulatory requirements of the regulatory body. Anti-money-laundering compliance management has become an important part of compliance risk management and internal control of commercial banks. However, compared with the practice of foreign banks over the years, there are still many gaps in anti-money laundering compliance management of commercial banks in our country. The specific manifestations are as follows: first, the construction of anti-money laundering organizations and the development requirements of anti-money laundering do not match the requirements of the development of anti-money laundering, and the staff of anti-money laundering are scarce. Restricted the implementation of internal control system; Second, the risk identification method is single, the research and experience in money laundering risk identification measurement and evaluation is still less, and the ability of risk monitoring and risk control is relatively weak; Third, the internal control system needs to be improved, and the horizontal cooperation mechanism between anti-money laundering departments and business departments is weak, which affects the effectiveness of anti-money laundering; fourth, compliance risk management theory in anti-money-laundering risk control practice still has many shortcomings. The research on the optimization strategy of anti-money laundering compliance management of commercial banks enriches and perfects the anti-money laundering compliance management theory and provides a reference for commercial banks to improve the anti-money laundering compliance management. On the one hand, on the basis of establishing a mechanism of mutual integration of anti-money laundering management measures, establishing a coordination mechanism and sharing mechanisms, the operation of anti-money laundering is brought into centralized processing, so as to solve the problem of weak execution of anti-money laundering system and long management chain. It is beneficial to the management and control of anti-money laundering work by the administrative department of anti-money laundering, improves the management efficiency and strengthens the executive power; On the other hand, it puts forward some suggestions to optimize the anti-money laundering management system, and puts forward the key points for commercial banks' anti-money laundering compliance management, such as risk warning and risk assessment for anti-money laundering in business departments. Strengthening the risk monitoring means such as information sharing enriches the methods of risk monitoring and is of great significance to improve the effectiveness of anti-money laundering management of commercial banks.
【学位授予单位】：山东大学
【学位级别】：硕士
【学位授予年份】：2014
【分类号】：F832.2
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