Please use this identifier to cite or link to this item: http://hdl.handle.net/10609/134666
Title: Evaluación supranacional de riesgos de blanqueo de capitales y financiación del terrorismo de la Unión Europea: propuesta de un mapa de riesgos
Author: Mena Marcos, Joaquín José
Tutor: Torra, Salvador  
Abstract: This research studies the adequacy and feasibility of the application of prediction and simulation techniques in the assessment of risk in the anti-money laundering and counter terrorist financing (AML-CFT) in order to: know the potential improvement of the current models of risk analysis in ML/TF provided for in Article 32 (RD 304/2014) based on historical data; strengthen the assurance of compliance with the regulations in force in Spain (Act 10/2010, RD 304/2014, SEPBLAC Recommendations, etc.); and to support the decision-making of obliged entities (financial and non-financial entities) and non-obliged subjects (criminal liability of legal persons). The methodology is based on the author's participant observation as an expert in AML-CFT. The risk of ML/TF has been studied synthetically using the phenomenological aspect of ML/TF and the risk-based approach. The AML-CFT systems have been emphasized as the result of a regulated self-regulation for obliged subjects who will use both hardlaw and softlaw sources of information. Along with the current regulations on risk analysis, concepts provided by COSO in enterprises risks and the risk assessment techniques of the consequence/probability matrix and Monte Carlo simulation included in the UNE-EN 31010 have been highlighted. Through the study of the methodology of the Supranational risk assessment of the money laundering and terrorist financing risks affecting the Union (SNRA 2017-2019) and the National Analysis of Risks of Money Laundering and Terrorist Financing (ANR-2020) it has been found that the European Union does not assess the "consequence" component of the residual risk matrix, considering it constant. The ML/TF residual risk matrix becomes the combination of threats and vulnerabilities. Against this background, risk maps have been drawn up of the different sectors, services or products considered in the SNRA and the ANR. The comparative analysis carried out has been from the data offered by the SNRA-2019 and the ANR-2020. This paper presents a proposal for a basic model or algorithm to calculate the residual risk of an obligated subject based on the methodologies of the SNRA-2017 and the ANR-2020. This model complements the risk analysis provided for in Article 32 (RD 304/2014) with numerical fair values. Historical data can be analyzed with tools such as R-Commander (multivariate analysis). Applying simulations by the Monte Carlo method (the tool @RISK PALISADE UOC license has been used) the probability of residual risk in a future fiscal year can be predicted. In any case, reasonable information is provided for decision-making in the processes of continuous improvement of AML-CFT systems.
Keywords: money laundering
terrorist financing
threats and vulnerabilities
risk maps
risk assessment
Document type: info:eu-repo/semantics/masterThesis
Issue Date: 7-Jul-2021
Publication license: http://creativecommons.org/licenses/by-nc-nd/3.0/es/  
Appears in Collections:Trabajos finales de carrera, trabajos de investigación, etc.

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