Catalog

	Table of Contents
p. 16 of 19 BACK | NEXT I. Executive Summary II. The Policy Context III. International Efforts to Combat Money Laundering and the Financing of Terrorism IV. The Policy V. Implementing the Policy A. Implementation and Monitoring B. Review of the Policy C. Resource Implications VI. Recommendation

Enhancing the Asian Development Bank's Role in Combating Money Laundering and the Financing of Terrorism : V. Implementing the Policy

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A. Implementation and Monitoring

76. In view of the fact that AML and CFT issues include aspects requiring different types of skills and expertise, the implementation of the policy will involve several departments and offices of ADB. The principal challenge facing ADB staff initially will be to gradually and systematically incorporate AML issues (and CFT issues to a more limited extent) into all relevant aspects of policy dialogue with DMCs and into loan and TA operations for which the regional departments will be primarily responsible; and also into ADB’s own administration of its financial operations and procurement-related activities for which the Office of the General Auditor (OGA), Central Operations Services Office (COSO), Controller's Department (CTL), Treasurer's Department (TD), and Private Sector Operations Department (PSOD) will share responsibilities. RSDD and OGC will support the work of departments/offices in the ways elaborated below so that the regional departments can provide appropriate assistance to the DMCs, being fully aware of ADB-wide activities and efforts by other institutions. Given the importance and need for close consultation and collaboration among departments and offices, the existing informal network of staff for AML/CFT matters will need to be developed into a formal network to act as a forum for regular interdepartmental discussions and coordination to implement the policy. The network will discuss and establish as early as possible a specific and preferably time-bound action plan and scope of work for the policy implementation. RSDD should be responsible for the formation and the operation of this network.

77. The regional departments will assist the DMCs in establishing and implementing effective AML/CFT systems through enhanced policy dialogue and provision of loans (or inclusion of loan components) and TA, as appropriate. They will also explore ways of enhancing regional and subregional cooperation among DMCs as well as enhancing public-private partnerships in DMCs in consultation with RSDD and OGC as appropriate. As for DMCs where no concrete project is being implemented, processed, or planned, the regional departments will first identify whether it is appropriate for each DMC to include AML/CFT issues in the policy dialogue and then in the CSP/CSPU and SCSP/SCSPU. Where inclusion in the CSP/CSPU and SCSP/SCSPU is deemed appropriate, best efforts should be made to do so in those for 2004. The regional departments will take into account the latest developments of international and regional efforts concerning AML/CFT when forming their assistance to DMCs. The regional departments will also attend, when appropriate, selected regional forums and countryspecific aid coordination meetings to ensure good coordination with other TA providers.

78. RSDD will monitor the implementation of the policy through operation of the staff network and periodic reviews. It will also provide technical advice to the regional departments as appropriate. RSDD will also be responsible for preparing and conducting staff training programs in coordination with OGC, BPMSD, and external experts. RSDD will attend, when appropriate, selected international and regional forums in coordination with OGC, the regional departments, and others.

79. OGC will continue to provide legal advice and other information on the latest developments in the global and regional efforts for AML/CFT. OGC, in coordination with relevant departments/offices, will continue to attend selected international and regional meetings and workshops as appropriate. OGC will further develop the current close working relationship with other international organizations active in AML/CFT in line with this policy. OGC will assist RSDD in the formation of the staff network to discuss an action plan and scope of work for the policy implementation. OGC will also prepare and conduct staff training programs in coordination with RSDD, BMPSD, and external experts.

80. OGA, COSO, CTL, TD, and PSOD will continue to seek and incorporate international best practices to safeguard ADB’s funds against misuse, within its mandate and responsibilities and in close coordination with other concerned departments and offices.

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