Professional linguists operating in the financial translation field can, and should, intervene in the fight against crimes such as corruption, money laundering and data theft. Their participation in reasonable due diligence when processing sensitive documents in a foreign language can take place mainly at five levels: preliminary review of the documents, information on their origin, verification of facts, knowledge of LBC techniques and compliance with the BSI10500 standard.
Preliminary review of documents to translate
In an article published in the BCC paper, David Clark explains that the first precaution to take is not to put the cart before the horse. There is often a strong temptation to start with a complete translation of all documents before examining the translated content. But it can represent a significant waste of time, as well as unnecessary costs. On the contrary, a structured approach to risk is preferable, based on a collaboration between professionals in the financial department and the specialized financial translation services: the process begins with a review of the documents in the foreign language in order to identify possible fraud risks. For example, the compliance manager concerned will be able to highlight the most relevant information as well as potentially suspicious elements. This data will then be translated as a priority, and their analysis, prior to the translation of the rest of the documentation, will allow informed decision-making and save time and money.
Information on the source of the documents
The translator should also be encouraged to use their sector expertise and local knowledge to learn about the source and source of the material. They could also be commissioned to identify, extract and examine certain key data. This procedure adds an additional and independent step to the due diligence and thorough review process. However, so that the translations hold up, they must be certified by the translator or the financial translation company.
Another step is to check facts. It is the compliance manager who will be in charge, but the linguist´s skills can also be put to good use here. Their knowledge of the local market as well as their analytical and research skills can help identify irregularities, which could indicate any suspicious activity in the documents or conversations. This is particularly the case during the customer knowledge phase (KYC). Similarly, such comments may be made in the case of a notification during the review and initial translation of the document.
Knowledge of LBC techniques
Finally, professionals in the fight against money laundering and compliance, customer relations staff and linguists should be trained to understand the specific risks associated with multilingual documents, and how to effectively minimize those risks. It would be good if the knowledge shared in this framework included investigative tools and techniques used by law enforcement professionals, case studies of best practices and examples not to be followed, and criminal typologies describing attempts to circumvent anti-corruption and AML procedures.
Compliance with BSI10500 standard
The standard British anti-bribery BSI10500 has become an unavoidable form of certification, especially for British companies operating abroad, who want to ensure that their anti-bribery procedures are adequate. While it is true that this standard is specific to British law, committed companies will ensure that they are in compliance in all their operations and in all jurisdictions. To do this, a trusted financial translation service is essential. Indeed, reasonable diligence, in this area, and particularly in legal and financial operations abroad, must include what can be avoided by language, insofar as misinformation or poor communication, which are often the origin of international criminal activity.
Detailed audit staff and language service providers are essential in the fight against fraud and corruption. Taking into account the risks associated with the language is crucial in this regard.
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