Anti-Financial Crime Partnerships
|
|
- Silas Bridges
- 5 years ago
- Views:
Transcription
1 Anti-Financial Crime Partnerships
2 Agenda Main Theme: ANTI-FINANCIAL CRIME PARTNERSHIPS 13:30 13:45: Quick intro on the Chapter and possibly the AML/CFT news in the region First Sub-topic: Intra-national public/private cooperation 13:45 14:05: Keynote - The UK s Joint Money Laundering Intelligence Taskforce (JMLIT) 14:05 14:25: Keynote - Latvian achievements on the informal sharing of information 14:25 15:00: Panel discussion - Intra-national public/private cooperation in the Baltics and elsewhere 15:00 15:15 : Coffee break Second Sub-topic: National registers & technical implementation 15:15 15:45: Keynote - Financial institutions cooperation with national registers 15:45 16: 30: Panel discussion - National registers & technical implementation in the Baltics and elsewhere 16:30 16:50: Wrap-up & Closing remarks 16:50 18:00: Networking & Cocktail
3 Welcome word & Chapter s update Uldis Upenieks Member of the Management Board, Chief Compliance AS "Citadele Banka & Co-chair, ACAMS Baltics Chapter Alexandre Pinot Head of AML & Simplex & Co-chair, ACAMS Baltics Chapter
4 The UK s Joint Money Laundering Intelligence Taskforce (JMLIT) Charles Richiardi Senior Financial Intelligence Officer, National Economic Crime Centre, UK
5 JOINT MONEY LAUNDERING INTELLIGENCE TASKFORCE
6 Co-operation with the financial sector provides mutual benefit, particularly where expertise is decentralised Non-judicial outcomes and detection/disruption tactics assist to mitigate the threat
7 The Threat & Background to JMLIT Strategic Defence & Security Review Illicit finance one of top 5 S&SOC threats Key commitments to enhance response National Risk Assessment JMLIT aligned to prioritised risks High end money laundering Cash money laundering Professional enablers Terrorist Financing Financing of other priority crime areas (eg Modern Slavery) JMLIT addresses issues raised in 2015 Improving information sharing Improving awareness of ML risks And those reiterated in 2018 SOC strategy
8 What is the JMLIT? A Public-Private Partnership between Law Enforcement, Government and the Financial Sector A Collaborative approach to the sharing of financial information A mechanism to: - allow the banking sector to work with law enforcement in line with their regulatory requirements and improve the collective understanding of the money laundering threat (Detect) - improve prioritisation of risks by financial institutions and inform the strengthening of banks systems and controls (Protect) - inform the prosecution and disruption of money laundering activity and allow law enforcement to establish a comprehensive understanding of financial information relating to a case (Disrupt)
9 Overview: JMLIT Structure
10 Overview: The Experts Groups 1) Trade Based ML 2) 2) ML Through Markets 3) OIC / MSHT 4) Proceeds of Corruption 5) Terrorist Finance 6) Future Threats Bank led (one exception) Recognised experts Wider membership Bimonthly Alerts shared widely (UKF Portal) Common language Changes to transaction monitoring rules Improved SARs (using JMLIT code) RBA: better targeting of resource
11 JMLIT Operations Group Live requests for intelligence 1) Operational context 2) Intelligence gaps 3) Operational objectives Weekly case briefings 1) Do banks have points of clarification? 2) Do banks have additional 3) capabilities/suggestions for the SIO? Proportionality & Justification Investigation Potential
12 Overview: JMLIT Operations Group Members
13 Overview: The Operations Group Benefits Case officers have access 17 UK Financial Institutions (covering 93% of the UK retail market and a wide range of international correspondent banking networks) as well as a number of public sector bodies One request to multiple institutions = efficient means to develop a comprehensive intelligence picture Follow up s7s - a virtuous circle Efficient targeting of evidential enquiries (saves LE, courts and banks time and money) Sharing of expertise, knowledge and awareness (eg correspondent banking, IP address data) Forum for member referrals tasking into LE (eg Op R, Op P) Inform and enhance financial sector understanding of risk / resource deployment Infrastructure to link tactical and strategic intelligence and response
14 Linking the Ops and Experts Groups Case Study: Human Trafficking Over 50 individuals trafficked for exploitation in dozens of brothels 4 previously unknown suspects identified by Ops JMLIT Multiple previously unknown accounts identified and closed. These accounts also identified new victims, allowing them to be safeguarded. 5 UK arrests, including 1 professional enabler Further 15 Romanian arrests in coordination with UK team
15 Case Study (cont): Alerts and the Link Between Operations and Experts Groups Indicators Flights to / from eastern Europe No corresponding economic activity in eastern Europe Regular cash deposits in UK Payments to adult services websites Rental of high end apartments Analysis of transaction patterns New individuals identified Intel Developed JMLIT / ECC Referral to UKHTC for Action
16 SAR Impact 2015 TBML EWG launches June/July TBML alerts October rd party payment alert May 2016 Major TBML product with case studies and red flags June 2017 Corporate client alert August 2017 Trade finance alert
17 A complex case CFA? Funds Associations
18 Summary of outcomes 486 cases developed 18.5m under restraint 125 Arrests 3700 accounts identified that were not previously known to law enforcement 3500 bank led investigations begun 3000 accounts closed / under heightened monitoring 35 Alerts 2200 JMLIT SARs (many from non-jmlit banks) 140 Enhancements to bank AML SYSC Collaboration / mutual understanding / efficiency
19 PPP The Future? Data and Analytics Project Athena Private to private sharing? Criminal Finance Act Co-location? National Economic Crime Centre Follow the money exercises Expansion & cross sector engagement? Insurance? Accountancy? Audit? Wealth banks? Impact on current operations model International engagement between PPPs Global network (Singapore, HK, US, NZ, NL etc)
20 Co-operation with the financial sector provides mutual benefit, particularly where expertise is decentralised Non-judicial outcomes and detection/disruption tactics assist to mitigate the threat
21 Questions?
22 Information Sharing Partnerships in Fighting a Financial Crime Latvian experience and achievements Jānis Brazovskis, CAMS Member of the Board ACAMS Baltics Chapter Finance Latvia Association
23 Safe Harbor Arrangements for Information Sharing Partnerships Forging of robust AML/CFT related information sharing arrangements is demanding commitment in any jurisdiction Latvian legislation along with other jurisdictions was kept for long years as a bulletproof safe box of banking secrecy Vital role of the Parliament, Government, Prosecution Office, Latvian FIU, Ministry of Justice, Ministry of Finance, State Revenue Service, Ministry of Interior, Corruption Prevention and Combating Bureau and Financial and Capital Markets Commission in enshrining of Safe Harbour Arrangements in legislation Significant input from Rick McDonell, ACAMS Executive Director and Former Executive Secretary of FATF and Angela Salter, Head of Europe, ACAMS in a better understanding of effectiveness and importance of private-public sector partnerships to prevent financial crime during our previous High-Level AML/CFT workshop on November 8, 2017 in Riga Thank you to our working partners from UK and USA for the sharing of experience in setting-up of public private information sharing partnerships
24 Towards Highest AML/CFT Compliance Standards Council of the Finance Latvia Association approved Policy Guidance and Guidelines on AML/CFT in October, 2017 Re-confirmed commitment to reach the highest AML/CFT compliance standards within the next 2 to 3 years, effectively fight financial crime and reduce inherent risks and risk appetite AB&C and Information sharing policies were added to Guidelines in October, 2018
25 Private Private Information Sharing Arrangements Among financial institutions (FI): within a FI s consolidated group; on STR/SAR submitted to FIU in relation to a customer s transactions; regarding the cut-off customers or refused to on-board customers due to suspicions on possible involvement in ML/TF or other serious FC; within Coordination Platform governed by FIU (UK JMLIT model).
26 Finance Latvia Association private private information sharing guidelines Provide accurate and concise information and ensure that it is up-to-date Share only ML/TF risks related information Exclude straight forward use of the received information as a sole basis for off-boarding of the customer or refusing to begin cooperation with a potential customer Do not share information if the customer refuses to submit any documents or in case of derisking demanded by the legislation or performed due to risk appetite of FI The information provided should allow unambiguous identification of the person, argumentation and a short substantiation of identified ML/TF risks The FI also indicates the persons associated with the customer: UBO, authorized representatives and other persons associated with the customer, in case they have aggravated ML/TF risks in the specific case (to be properly disclosed)
27 Co-operation with State Revenue Service (SRS) Co-ordination group between Finance Latvia Association and SRS has been established Appointed liaison officers from Finance Latvia Association, FIs and SRS to facilitate communication Regular expert meetings Tailored legal framework for information sharing partnership adopted on November 1, 2018 Three ways for information sharing: a. by submitting a SAR to SRS; b. by providing additional data on the particular already submitted SAR; c. voluntary co-operation and information sharing partnership with SRS to fight tax evasion (SAR s submission is not a precondition for co-operation). Example, SRS might ask FI to analyze customers with certain parameters (pre-discussed and coordinated in the co-ordination group) and communicate analysis out-come to SRS for further indepth analysis. SAR is filed, if the analysis commands it
28 Various Public Private Information Sharing Arrangements Filing of SARs/STRs Account register Company Register (information on UBOs) Coordination Platform governed by FIU (UK JMLIT model)
29 Evolving Role of State Registries in Information Sharing Account Register (operated by SRS): FIs share information with statutory authorized governmental agencies regarding UBOs identified by them during KYC/CIP processes Company Register: holds records of UBOs of companies filed by companies on their own. Submitting of inaccurate information is a criminal offence. Information on UBO is available to general public Registers are populated with required data. Smooth and effective interaction and cross-reference between these two databases would be beneficial for further enhancement of verification of customers, improvement of investigation of financial crime and serve as a trusted an reliable source of information for KYC Utilities
30 Latvian Public-Private Information Sharing Partnership Model FIU co-ordinates proper information sharing, may take part in information sharing as a full flagged partner Information is shared within designated co-operation group Cooperation group is allowed to share information on particular case and persons involved, and discuss typologies as well Its a two way traffic members of the group are bind to share information in good faith. Pure scooping of information is not legitimate Trust is a key for successful operation of the group/partnership Group enables faster investigation, reduces administrative burden, but still requires high level of accuracy and records trail
31 Latvian Public-Private Information Sharing Partnership Who is involved? Police intelligence units, investigatory authorities, Office of the Prosecutor, the SRS and any obliged entity. Participation of Latvian Regulatory Authority FCMC is optional one The FIU is entitled to select participants What is the scope? The involved institutions and entities upon their initiative are entitled, within the scope of the coordination group, to share information related to ML/TF, attempt to comit ML/TF, another criminal offence or suspicious transaction. Involved institutions are authorized to even examine information obtain in the course of investigation of specific cases
32 Key Tasks to be Resolved while Operationalize the Public Private Information Sharing Partnerships Continuous building of trust! Risk-based and focused training of the participants Education of officials and general public Expansion of the span of entities involved in partnerships Vetting of the private sector representatives involved in partnerships Regular and focused communication of the achievements of partnerships to professional audiences and general public
33 KYC Utility Perspective The Government has decided to assess introduction of KYC utility as a effective and reliable information sharing platform among obliged entities, firms and state registries KYC Utility may not be operational without proper, legally certain information sharing arrangements in place KYC Utility might raise unhampered information sharing among the FIs and the state from an exception to the general rule
34 Thank You!
35 Panel discussion Intra-national public-private, private-private cooperation in the Baltics and elsewhere Panelists: Charles Richiardi, Senior Financial Intelligence Officer, National Economic Crime Centre, UK Ilze Znotiņa, Head of Financial Intelligence Unit, Latvia Laila Medin, Deputy State Secretary, Ministry of Justice, Latvia Juris Bogdanovs, Head of GSI Investigations in Latvia, Swedbank Che Sidanius, Global Head of Financial Crime & Industry Affairs, Refinitiv Moderator: Jānis Kauliņš, Director & Financial Crime Practice Leader at Deloitte Central Europe
36 Coffee Break brought to you by
37 Financial institutions cooperation with national registers Vytautas Danta, CAMS Member of the Board ACAMS Baltics Chapter Head of Compliance, Swedbank Lithuania
38 Trends Requirements Tools Challenges
39 Financial institution are given by the laws a very important and mandatory role to prevent money laundering and terrorist financing know your customer know your customer activity prevent money laundering and terrorist financing report to authorities How does it fit with the new services such as digital onboarding?
40 How we act? Clients with doubtful and/ or non-transparent activities are not served Questions to the customers: Business activities performed? Jurisdictions operated in? Transactional activities performed? Who are the UBOs? Who are the key partners? Who are the target clients and partners? What control measures are implemented within the paying institution? Other
41 The most important thing in KYC process is information Information about customer Information collection and verification Information collection from ID documents, KYC questionnaire and verification in external data sources IT solution / employee Information screening Positive Data screening False Sanction lists PEP list Negative publicity IT solution / employee Risk scoring Depends on activity, geographical factors, etc. High Medium Low IT solution / employee Enhanced due diligence More detail analysis for the decision Decision regarding risk mitigation measures and possibilities to maintain business relations Employee REPORT TO FIU
42 Almost all KYC related information is available from state registers or institutions Data provider State register directly or intermediary Private individuals data Corporate customers data ID details, including picture, Shareholders Activity Official contact details Data collection Financial institution Data use for the onboarding and ongoing due diligence Financial institution
43 The main challenges and areas for the improvements Almost all mandatory KYC data is available in state registers, therefore it is common goal to ensure that financial institutions could be able to use it Cooperation between financial institutions are not effective so far, however there are some good examples There is no common information exchange standard on country level and cross border between state registers and financial institutions State registers should develop effective information exchange solutions which would allow all market participants to connect in the same way without expensive IT developments High data quality should be ensured in state registers, for example PEP and beneficial owners data Data exchange pricing (especially having in mind the current quality of data) is too high for the financial institutions and should be reviewed since financial institutions are implementing mandatory legal requirements
44 Expectations and potential next steps Key expectations: Machine readable / structured data available Key aspects / elements of data being collected (e.g., PEP status, sanctions, etc.) Timeliness of data / more frequent updates of data Centralized collection of data in 1 central point (centre of registers) Cross-country cooperation between (at least?) Baltics Changes required: Change of laws & requirements for companies? More strict monitoring of data quality? (including bigger fines to companies not providing data on a timely basis and/ or providing inaccurate data?) Cross-governmental agreements regarding exchange of data?
45 Thank You!
46 Panel discussion Cooperation amongst national registers and financial institutions - Technical tools in the Baltics and elsewhere Panelists: Laima Letiņa, Deputy Head of the Legal Department, Register of Enterprises, Latvia JMLIT, the UK model for PPP: Results achieved so far, lessons learned The Latvian approach to PPP View from the industry The way forward, given emerging technologies, trends and threats Moderator: Liudas Jurkonis, Member of the Board ACAMS Baltics Chapter, Leader of EY s forensic & integrity practice for the Baltic States
47 Wrap-up & Closing remarks Vytautas Danta, CAMS Member of the Board ACAMS Baltics Chapter Head of Compliance, Swedbank Lithuania
48 Networking & cocktail brought to you by
Anti-Money Laundering Policy June 2017
Anti-Money Laundering Policy June 2017 1 1. Introduction The Bank has a legal, moral and social responsibility to its customers to deter and detect those who would seek to use United Bank UK (UBL UK) to
More informationPolicy on Anti Money Laundering and Countering Terrorist Financing
Policy on Anti Money Laundering and Countering Terrorist Financing Adopted by Date of adoption Applies for Group Framework Owner Distribution Language version Information class Basis the Board 22 June
More informationAnti-money laundering Annual report 2017/18
Anti-money laundering Annual report 2017/18 Anti-money laundering Contents 1 Introduction 4 2 Policy developments 5 3 OPBAS 7 4 How our AML supervision is evolving 8 5 Findings and outcomes 9 6 Financial
More informationSTEP CERTIFICATE IN ANTI-MONEY LAUNDERING. Syllabus
STEP CERTIFICATE IN ANTI-MONEY LAUNDERING Syllabus In collaboration with Delivered by INTRODUCTION This document contains the detailed syllabus for the. This syllabus should be read in conjunction with
More informationWebinar 01: AML/CFT Requirements Overview. 4 th July 2018
Webinar 01: AML/CFT Requirements Overview 4 th July 2018 About Your Presenter Neil has a unique background in financial crime risk management, spanning 25 years. This includes working within Law Enforcement
More informationJuly 2017 CONSULTATION DRAFT. Guidelines on. Anti-Money Laundering. and. Counter-Terrorist Financing for Professional Accountants
July 2017 CONSULTATION DRAFT Guidelines on Anti-Money Laundering and Counter-Terrorist Financing for Professional Accountants CONTENTS Page SUMMARY OF MAIN REQUIREMENTS... 4 Section 1: OVERVIEW AND APPLICATION...
More informationExecutive Summary EXECUTIVE SUMMARY. Key Findings. Preface
Executive Summary Preface EXECUTIVE SUMMARY 1. This report provides a summary of the anti-money laundering and combating the financing of terrorism (AML/CFT) measures in place in Singapore as at the date
More informationAML/CFT TRAINING FOR ACCOUNTANTS AND AUDITORS
AML/CFT TRAINING FOR ACCOUNTANTS AND AUDITORS 1 16 MARCH 2016 BANK USE PROMOTION & SUPPRESSION OF MONEY LAUNDERING UNIT 2 3 What is Money Laundering? the process of concealing illicit gains from criminal
More informationfinancial intelligence centre REPUBLIC OF SOUTH AFRICA Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre
Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre 3 December 2013 Agenda The FIC Functions of the FIC Value Chain FIC - 2012/2013 in review Compliance framework
More informationDFSA Annual Supervision Outreach Breakout Group # 3 Financial Crime Risks. 25 June 2018
DFSA Annual Supervision Outreach Breakout Group # 3 Financial Crime Risks 25 June 2018 Breakout Group 3 - Agenda Opening Comments - Lawrence Paramasivam Director, Supervision General updates from the Financial
More informationCORRUPTION. A Reference Guide and Information Note. on the use of the FATF Recommendations. to support the fight against Corruption
FINANCIAL ACTION TASK FORCE CORRUPTION A Reference Guide and Information Note on the use of the FATF Recommendations to support the fight against Corruption The Financial Action Task Force (FATF) is the
More informationA NATIONAL RISK ASSESSMENT REGARDING AML-CFT
A NATIONAL RISK ASSESSMENT REGARDING AML-CFT Symposium `Enhancing Integrity in the Dutch Caribbean` Aruba, November 15, 2010 Mrs. J.A. Kellermann De Nederlandsche Bank Executive Director Overview Introduction
More informationFATF Mutual Evaluation of Ireland 2017
FATF Mutual Evaluation of Ireland 2017 Introduction Background The Financial Action Task Force ( FATF ) was established in 1989 with a high level objective that: Financial systems and the broader economy
More informationDEVELOPMENT BANK OF IRAN (EDBI)
EXPORT DEVELOPMENT BANK OF IRAN (EDBI) Anti-Money Laundering and Combating Financing of Terrorism Policies Target audience: Employees and Management of EDBI Approved by: EDBI s Board of Directors, at 2018/05/21
More informationRegistry General September 2015
Registry General September 2015 1 Charities Compliance Officer Training Topics What is FATF? How FATF relates to charities Guidance Notes on the Charities (Anti-Money Laundering, Anti-Terrorist Financing
More informationCONTINENTAL REINSURANCE ( C Re ) ANTI-MONEY LAUDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) POLICY
CONTINENTAL REINSURANCE ( C Re ) ANTI-MONEY LAUDERING/COUNTERING THE FINANCING OF TERRORISM (AML/CFT) POLICY (Approved by the Board of Directors on March 5, 2014) 1 1. Introduction The C Re group is cognizant
More informationAnti-money laundering and countering the financing of terrorism the Reserve Bank s responsibilities and approach
Anti-money laundering and countering the financing of terrorism the Reserve Bank s responsibilities and approach Hamish Armstrong Taking action to reduce money laundering and the financing of terrorism
More informationOVERVIEW OF THE QFC AML REGIME
OVERVIEW OF THE QFC AML REGIME Prasanna Haran, Director Supervision Vanessa Read, Acting Head AML Supervision Christiane Chidiac, Manager AML Supervision AGENDA Objectives of the AML industry seminars
More informationAML/CFT Phase II. Kate Reid NZLS CLE live stream 28 November /11/2017. Check it out by logging in at:
Check it out by logging in at: www.lawyerseducation.co.nz AML/CFT Phase II Kate Reid NZLS CLE live stream 28 November 2017 1 What this presentation is about Phase II what and why What you have to do What
More informationFATF Report to the G20 Finance Ministers and Central Bank Governors
FATF Report to the G20 Finance Ministers and Central Bank Governors April 2019 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect
More informationAnti Money Laundering - Financial Crime Compliance
Anti Money Laundering - Financial Crime Compliance Blockchain Technology, De-Risking And Money Laundering In the Financial Services Sector (Banks & Non Banks) This course is presented in London on: 11-12
More informationAnti-Money Laundering and Counter Terrorism
1 Anti-Money Laundering and Counter Terrorism 1. INTRODUCTION SimpleFX Ltd. ( The Company ) aims to prevent, detect and not knowingly facilitate money laundering and terrorism financing activities. The
More informationFinancial Crime Governance, Risk and Compliance Fund Managers & Fund Administrators. Thematic Review 2017
Financial Crime Governance, Risk and Compliance Fund Managers & Fund Administrators Thematic Review 2017 Foreword During late 2016 a thematic review of fund managers and fund administrators governance,
More informationHANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING
HANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING 18 September 2007 CONTENTS Part 1 Chapter Page Part 2 Part 3 1. Introduction 4. 2. Corporate Governance
More informationEmerging trends in global financial crime prevention and anti money laundering
Emerging trends in global financial crime prevention and anti money laundering Four key takeaways from the recent ACAMS conference in London Introduction The 13th Annual ACAMS European conference was held
More informationSUMMARY Seychelles National Risk Assessment Report for Money Laundering & Terrorist Financing 2017
SUMMARY Seychelles National Risk Assessment Report for Money Laundering & Terrorist Financing 2017 Introduction The National Risk Assessment (NRA) is a process of identifying and evaluating the Money Laundering
More informationBRIEFING NOTE ON THE BAILIWICK OF GUERNSEY S NATIONAL RISK ASSESSMENT 7 July 2016
BRIEFING NOTE ON THE BAILIWICK OF GUERNSEY S NATIONAL RISK ASSESSMENT 7 July 2016 Introduction The purpose of this briefing note is to provide financial services businesses, prescribed businesses and e-gambling
More informationTHE KINGDOM OF LESOTHO ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM REGIME
THE KINGDOM OF LESOTHO ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM REGIME ----------------------------------------------------------------- NATIONAL STRATEGY JANUARY 2010 1 TABLE OF
More informationExecutive Summary. A. Key Findings
Executive Summary 1. This report provides a summary of the anti-money laundering and combating the financing of terrorism (AML/CFT) measures in place in Portugal as of the date of the on-site visit (28
More informationThe Handbook. Sator Regulatory Consulting Limited. Helen M Hatton, Managing Director
The Handbook Sator Regulatory Consulting Limited Helen M Hatton, Managing Director THE NEW AML REGIME CBA OVERSIGHT THE NEW HANDBOOK STANDARDS Law and Regulation The State Ordinance on the Prevention and
More informationAnti-Money Laundering Awareness Training Insurance Industry-Hong Kong
Anti-Money Laundering Awareness Training Overview This program is intended to give individuals working in the Hong Kong Insurance Industry a basic knowledge of money laundering and terrorism financing,
More informationEXECUTIVE SUMMARY. 4. Individuals and groups seeking to
CONCEALMENT OF BENEFICIAL OWNERSHIP 5 EXECUTIVE SUMMARY 1. Criminals employ a range of techniques and mechanisms to obscure their ownership and control of illicitly obtained assets. Identifying the true
More informationANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING PROCEDURE MANUAL. Fcorp Services Ltd
ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING PROCEDURE MANUAL Fcorp Services Ltd The manual is property of Fcorp LTD The reproduction in whole or in part in any way including the reproduction
More informationFINANCIAL CRIME GUIDE (AMENDMENT NO 3) INSTRUMENT 2015
FINANCIAL CRIME GUIDE (AMENDMENT NO 3) INSTRUMENT 2015 Powers exercised A. The Financial Conduct Authority makes this instrument in the exercise of its powers under: (1) section 139A (Guidance) of the
More informationAnti-Money Laundering and Counter-Terrorist Financing Seminar
Anti-Money Laundering and Counter-Terrorist Financing Seminar November / December 2017 Raymond Wong, Director Irene Pou, Associate Director Ivan Wan, Senior Manager Intermediaries Supervision Department,
More informationAML & KYC. The Crime Prevention Compliance Course. This course can be presented in-house for you on a date of your choosing
AML & KYC The Crime Prevention Compliance Course This course can be presented in-house for you on a date of your choosing The Banking and Corporate Finance Training Specialist Course Overview Financial
More informationHANDBOOK FOR LEGAL PROFESSIONALS, ACCOUNTANTS AND ESTATE AGENTS ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING
HANDBOOK FOR LEGAL PROFESSIONALS, ACCOUNTANTS AND ESTATE AGENTS ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING September 2008 (updated July 2016) CONTENTS PART 1 Page CHAPTER 1 INTRODUCTION... 4
More informationGUIDELINES ON RISK-BASED APPROACH (RBA) FOR THE PURPOSE OF ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (AML/CFT)
GUIDELINES ON RISK-BASED APPROACH (RBA) FOR THE PURPOSE OF ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (AML/CFT) Guidelines on Risk-Based Approach (RBA) for the purpose of Anti-Money
More information4th Anti-Money Laundering Directive and 2d Fund Transfers Regulation- General overview and impact on payments
4th Anti-Money Laundering Directive and 2d Fund Transfers Regulation- General overview and impact on payments Payment systems market expert group Brussels, 3 December 2015 European Commission DG Justice
More informationResponse to New Zealand s consultation paper on Phase Two of the AML/CFT Act
Date: 14 September 2016 Introduction Response to New Zealand s consultation paper on Phase Two of the AML/CFT Act Thomson Reuters welcomes the opportunity to respond to this consultation and thanks the
More informationPolitically Exposed Persons (PEPs) in relation to AML/CFT
Middle East & North Africa Financial Action Task Force Politically Exposed Persons (PEPs) in relation to AML/CFT 11 November 2008 Document Language: English Original: Arabic 2008 MENAFATF. All rights reserved.
More informationHANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING. 15 December 2007 (updated July 2016)
HANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING 15 December 2007 (updated July 2016) CONTENTS Part 1 Page CHAPTER 1 INTRODUCTION 4 CHAPTER 2 CORPORATE GOVERNANCE
More informationSWITZERLAND BENEFICIAL OWNERSHIP TRANSPARENCY
SWITZERLAND BENEFICIAL OWNERSHIP TRANSPARENCY Switzerland is fully compliant with two of the G20 Principles. The establishment of a beneficial ownership registry could significantly strengthen the ability
More informationFATF Report to the G20 Finance Ministers and Central Bank Governors
FATF Report to the G20 Finance Ministers and Central Bank Governors March 2018 FINANCIAL ACTION TASK FORCE The Financial Action Task Force (FATF) is an independent inter-governmental body that develops
More informationWIND OF CHANGE: Risk Assessment. Anti-Money Laundering, Countering Terrorism Financing, Application of International Sanctions
WIND OF CHANGE: Risk Assessment Anti-Money Laundering, Countering Terrorism Financing, Application of International Sanctions The 4th EU Anti-Money Laundering Directive encompasses significant changes
More informationObjectives for FATF XXV ( ) Paper by the incoming President
Objectives for FATF XXV (2013-2014) Paper by the incoming President Main tasks for the FATF in 2013-2014, in line with the Ministerial Mandate of 20 April 2012: I. INTRODUCTION Promoting and facilitating
More informationAnti-Money Laundering & Financial Crimes Conference April 18th 20th, 2018
Anti-Money Laundering & Financial Crimes Conference 2018 April 18th 20th, 2018 Know Your Customer's Customer (KYCC) The next level of due diligence obligations Introduction 1. FATF Standards, CDD and KYC
More informationGD 2017/0059 ISLE OF MAN FINANCIAL INTELLIGENCE UNIT Strategic Delivery Plan June 2017
GD 2017/0059 ISLE OF MAN FINANCIAL INTELLIGENCE UNIT Strategic Delivery Plan 2017-18 June 2017 CONTENTS Foreword...3 Introduction...4 Who we are...4 What we do...5 2 Strategic Objectives, as identified
More informationPROJECT AGAINST CORRUPTION IN ALBANIA (PACA) TECHNICAL PAPER
PROJECT AGAINST CORRUPTION IN ALBANIA (PACA) TECHNICAL PAPER ASSESSMENT OF THE REVISED PROPOSED AMENDMENTS TO THE LAW ON PREVENTION OF MONEY LAUNDERING AND TERRORISM FINANCING Opinion of the Department
More informationANTI-MONEY LAUNDERING/ COUNTER FINANCING OF TERRORISM GUIDELINES FOR REGISTERED FILING AGENTS
ANTI-MONEY LAUNDERING/ COUNTER FINANCING OF TERRORISM GUIDELINES FOR REGISTERED FILING AGENTS Published 17 Oct 2017 TABLE OF CONTENTS 1 INTRODUCTION... 2 2 APPLICATION OF THESE GUIDELINES... 2 2.1 Definitions
More information(Revised: 7 December 2016)
Summary of Amendments and Introduction of New Obligations to the Guidelines on Prevention of Money Laundering and Terrorism Financing for Capital Market Intermediaries (Revised: 7 December 2016) The following
More informationMr Chua Kim Leng, Special Advisor (Financial Supervision Group), Monetary Authority of Singapore
SPEECH BY MR DAVID CHEW, DIRECTOR, COMMERCIAL AFFAIRS DEPARTMENT, SINGAPORE POLICE FORCE, AT THE AML/CFT INDUSTRY PARTNERSHIP ( ACIP ) DIALOGUES ON MONDAY, 14 MAY 2018 Mr Chua Kim Leng, Special Advisor
More informationThis course is presented in London on: March 2018, October The Banking and Corporate Finance Training Specialist
Anti Money Laundering - Financial Crime Compliance Blockchain Technology, De-Risking And Money Laundering In the Financial Services Sector - (Banks & Non Banks) This course is presented in London on: 19-20
More informationCommon approach across Hong Kong AML regulators
Response to the Securities and Futures Commission s Consultation Paper on Proposed Amendments to the (1) Guideline on Anti-Money Laundering and Counter-Terrorist Financing and (2) Prevention of Money Laundering
More informationAUSTRAC Guidance Note. Risk management and AML/CTF programs
AUSTRAC Guidance Note Risk management and AML/CTF programs AUSTRAC Guidance Note Risk management and AML/CTF programs Anti-Money Laundering and Counter-Terrorism Financing Act 2006 Contents Page 1. Introduction
More informationANTI-MONEY LAUNDERING/ COUNTERING THE FINANCING OF TERRORISM STRATEGY GROUP
ANTI-MONEY LAUNDERING/ COUNTERING THE FINANCING OF TERRORISM STRATEGY GROUP AN ISLAND STRATEGY TO COUNTER MONEY LAUNDERING AND THE FINANCING OF TERRORISM UPDATE MARCH 2011 Contents 1 Introduction...3 2
More informationMoney Laundering and Terrorist Financing Risk Assessment and Management
Money Laundering and Terrorist Financing Risk Assessment and Management 1. 1 Introduction Overview of ML&TF Risk The success of AML&CFT program highly depends on efficient assessment of related threat/vulnerability/risk
More informationR.S.A. c. P98 Anti-Money Laundering and Terrorist Financing Code R.R.A. P98-5. Revised Regulations of Anguilla: P98-5
R.S.A. c. P98 Anti-Money Laundering and Terrorist Financing Code R.R.A. P98-5 Revised Regulations of Anguilla: P98-5 PROCEEDS OF CRIME ACT, R.S.A. c. P98 ANTI-MONEY LAUNDERING AND TERRORIST FINANCING CODE
More informationIn developing this product AML Accelerate draws on unique and unparalleled knowledge and experience contained within the joint venture partners.
Improving New Zealand s ability to tackle ML/FT We would like to thank the New Zealand Ministry of Justice for the opportunity to provide input into this important consultation on how to improve New Zealand
More informationNOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186
MAS 626 2 July 2007 Last revised on 23 January 2013 (Refer to endnotes for history of amendments) NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING
More informationAML & KYC. The Crime Prevention Compliance Course. This course can be presented in-house for you on a date of your choosing
AML & KYC The Crime Prevention Compliance Course This course can be presented in-house for you on a date of your choosing The Banking and Corporate Finance Training Specialist Course Overview Financial
More informationAnti-Money Laundering and Counter Financing to Terrorist (AML/CFT) Workshop Series: AML Compliance Policies / Programme within a company
Anti-Money Laundering and Counter Financing to Terrorist (AML/CFT) Workshop Series: AML Compliance Policies / Programme within a company Natalia Seng Chief Executive Officer China & Hong Kong Tricor Group
More informationSFC consultation paper on proposed anti-money laundering and counterterrorist
October 2011 SFC consultation paper on proposed anti-money laundering and counterterrorist Introduction On 1 April 2012, the new Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions)
More informationPreparing for becoming a reporting entity under the AML/CFT Act
PRACTICE BRIEFING Preparing for becoming a reporting entity under the AML/CFT Act Lawyers need to undertake three tasks to prepare themselves for becoming reporting entities under the Anti-Money Laundering
More informationAnti-Money Laundering. Renu Kiran
Anti-Money Laundering Renu Kiran Introduction The National Crime Agency estimates around 100bn a year of corrupt foreign money is laundered in the UK. Upmarket property, luxury goods and the British financial
More informationANNEX III Sector-Specific Guidance Notes for Investment Business Providers, Investment Funds and Fund Administrators
ANNEX III Sector-Specific Guidance Notes for Investment Business Providers, Investment Funds and Fund Administrators These sector-specific guidance notes should be read in conjunction with the main guidance
More informationANTI-MONEY LAUNDERING POLICY. (2 nd Edition)
APPROVED by the Board of Directors on 27 th of June, 2018 Effective from 16 th of July, 2018 ANTI-MONEY LAUNDERING POLICY (2 nd Edition) Riga, 2018 1 1. TERMS AND ABBREVIATIONS GRUPEER GRUPEER SIA, registration
More informationREPUBLIC OF NAMIBIA NATIONAL STRATEGY ANTI-MONEY LAUNDERING COMBATTING THE FINANCING OF TERRORISM
REPUBLIC OF NAMIBIA NATIONAL STRATEGY ON ANTI-MONEY LAUNDERING AND COMBATTING THE FINANCING OF TERRORISM 2 GLOSSARY AND ABBREVIATIONS ACC AML AMLAC BoN CFT DNFBPs ESAAMLG FATF FI Anti-Corruption Commission
More informationStrasbourg, 6 November 2015 C198-COP(2015)PROG3-ANALYSIS
Strasbourg, 6 November 2015 C198-COP(2015)PROG3-ANALYSIS CONFERENCE OF THE PARTIES Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing
More informationWifi: LBKonference Password: LBMeetingroom
Wifi: LBKonference Password: LBMeetingroom Wifi: LBKonference Password: LBMeetingroom The variables Requirements of the law Effective implementation by the covered financial institutions and DNFBPS
More informationANTI-MONEY LAUNDERING PROCESS MATURITY
ANTI-MONEY LAUNDERING PROCESS MATURITY NEPAL BANKING INDUSTRY Survey Report 2017 Survey Partner AML PROCESS MATURITY - NEPAL BANKING INDUSTRY Survey Report 2017 Anti-Money Laundering (AML) and Combating
More informationAl Rajhi Bank Malaysia Anti-Money Laundering Questionnaire
At Al Rajhi Bank Malaysia (ARBM), we are constantly striving to set higher standards i.e. at minimum to meet the international best practices in anti-money laundering and antiterrorism financing. For this
More informationAnti Money Laundering Policy
Anti Money Laundering Policy I. Definition of Money Laundering Money laundering is the process by which large amounts of illegally obtained money (from drug trafficking, terrorist activity or other serious
More informationNATIONAL STRATEGY AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM
Pursuant to Article 45(1) of the Law on Government (Official Gazette of RS, No 55/05, 71/05 corr., 101/07, 65/08, 16/2011, 68/2012 CC decision, 72/2012, 7/2014 CC decision and 44/2014), The Government
More informationAnti-Money Laundering Primer for Health Insurers
Anti-Money Laundering Primer for Health Insurers Health Care Compliance Association April 26, 2004 Stephen W. Koslow and Rhys W. Jones PwC Agenda The Crime of Money Laundering The Risk of Money Laundering
More informationUpdate No (Issued 28 February 2018) Document Reference and Title Instructions Explanations
Update No. 216 (Issued 28 February 2018) Document Reference and Title Instructions Explanations VOLUME I Contents of Volume I PROFESSIONAL ETHICS Code of Ethics for Professional Accountants (Revised) [Part
More informationANTI-MONEY LAUNDERING IN
ANTI-MONEY LAUNDERING IN THE ACQUIRING INDUSTRY Presented by Laura H. Goldzung, CAMS, CCFE, CFCF, CCRP AML Audit Services, LLC March 8, 2016 AGENDA AML Regulatory Overview OFAC Regulatory Overview AML
More informationThe Risk Factors Guidelines
JC 2017 37 04/01/2018 Final Guidelines Joint Guidelines under Articles 17 and 18(4) of Directive (EU) 2015/849 on simplified and enhanced customer due diligence and the factors credit and financial institutions
More informationAssessment of money laundering and terrorist financing risks in the Principality of Liechtenstein
Assessment of money laundering and terrorist financing risks in the Principality of Liechtenstein National Risk Assessment (NRA) Summary (for publication) July 2018 The first step in the risk management
More informationStatutory Review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
i Submission of the Federation of Law Societies of Canada to the House of Commons Standing Committee on Finance Statutory Review of the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
More informationPractical Implementation of UN Standards and Financial Action Task Force on Money Laundering (FATF) Recommendations: Challenges and Assistance
2007/ACT/WKSP/005 Practical Implementation of UN Standards and Financial Action Task Force on Money Laundering (FATF) Recommendations: Challenges and Assistance Submitted by: United Nations Office on Drugs
More informationThe Practical Impact of the FATF Mutual Evaluation on the US AML Professional
The Practical Impact of the FATF Mutual Evaluation on the US AML Professional Monday, April 3 1:30 PM Moderator: Rick McDonell, Executive Director, ACAMS, and Former Executive Secretary, Financial Action
More informationEXECUTIVE SUMMARY. Executive Summary. Key Findings
. Executive Summary 1. This report provides a summary of the AML/CFT measures in place in Ireland as at the date of the on-site visit from 3-17 November 2016. It analyses the level of compliance with the
More informationCONSULTATION PAPER NO JUNE 2016 PROPOSED CHANGES TO THE ANTI MONEY LAUNDERING, COUNTER- TERRORIST FINANCING AND SANCTIONS MODULE
CONSULTATION PAPER NO. 107 20 JUNE 2016 PROPOSED CHANGES TO THE ANTI MONEY LAUNDERING, COUNTER- TERRORIST FINANCING AND SANCTIONS MODULE CONSULTATION PAPER NO. 107 PROPOSED CHANGES TO THE ANTI MONEY LAUNDERING,
More informationFinancial Intelligence Centre Amendment Bill [B ]
Financial Intelligence Centre Amendment Bill [B 33 2015] Briefing of the Select Committee on Finance 20 May 2016 Presentation by National Treasury and Financial Intelligence Centre financial intelligence
More informationAnti Money Laundering - Financial Crime Compliance
Anti Money Laundering - Financial Crime Compliance Blockchain Technology, De-Risking And Money Laundering In the Financial Services Sector - (Banks & Non Banks) This course is presented in London on: 30-31
More informationCAYMAN ISLANDS MONETARY AUTHORITY
CAYMAN ISLANDS MONETARY AUTHORITY To: All Licensees From: Cayman Islands Monetary Authority Date: September 2017 Supervisory Issues and Information Circular On-Site inspections and the use of Requirements
More informationDate: Version: Reason for Change:
Applicant Name: Leo Tyndall Application Number: 89562543 Attachment Name: Number of Pages: 60 Date Prepared: 1/08/2014 Special Status (if any): Anti-Money Laundering and Counter-Terrorism Financing Policy
More informationAML/CTF and Sanctions Policy
AML/CTF and Sanctions Policy May 2018 Purpose and Objective The purpose of this policy is to set the high-level principles and standards of management of financial crime risks, including money laundering,
More informationRe: Compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 ( CJA 2010 )
Dear CEO 12 October 2012 Re: Compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 ( CJA 2010 ) Dear CEO, As of 15 July 2010 the Central Bank of Ireland ( Central Bank
More informationMoney Laundering and Terrorist Financing Risks in the E-Money Sector
Money Laundering and Terrorist Financing Risks in the E-Money Sector Thematic Review TR18/3 October 2018 TR18/3 Contents 1 Introduction 3 2 Overview 5 3 Findings 7 Annex 1 Glossary 16 How to navigate this
More informationPreparing for the 4 th Round of Mutual Evaluations ANGUILLA, FRIDAY 8 TH OF MAY 2015
Preparing for the 4 th Round of Mutual Evaluations ANA FOLGAR L EGAL ADVISOR CFATF ANGUILLA, FRIDAY 8 TH OF MAY 2015 Content The FATF Mandate Role of the CFATF in relation to FATF Involvement of CFATF
More informationConsultation Paper. The Review of the Standards Preparation for the 4 th Round of Mutual Evaluation. Second public consultation
Financial Action Task Force Groupe d action financière Consultation Paper The Review of the Standards Preparation for the 4 th Round of Mutual Evaluation Second public consultation June 2011 THE FINANCIAL
More informationRegulatory Update. MAS Circular to FMCs on Enhancing AML/CFT Measures ( CMI 03/2015 ) 9 November Overview
Water Dragon Solutions Pte Ltd, the Compliance Practice of Maroon Analytics 63 Robinson Road #04-04 Afro Asia Building Singapore 068894 +65 8192 1784 www.maroonanalytics.com Regulatory Update 9 November
More informationBlueOrange MAJOR ENHANCEMENTS IN AML/CTF COMPLIANCE AND OTHER RELEVANT DEVELOPMENTS
BlueOrange MAJOR ENHANCEMENTS IN AML/CTF COMPLIANCE AND OTHER RELEVANT DEVELOPMENTS FACTSHEET MAJOR ENHANCEMENTS IN AML/CTF COMPLIANCE AND OTHER RELEVANT DEVELOPMENTS PROFILE OF THE BANK Bank was registered
More informationProposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
EUROPEAN COMMISSION Strasbourg, 17.4.2018 COM(2018) 213 final 2018/0105 (COD) Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down rules facilitating the use of financial
More informationDo You Know Your Customer? 2017 Asset Management & Operations Servicer Workshop
Do You Know Your Customer? 2017 Asset Management & Operations Servicer Workshop Presenters Mike Kenney Senior Director Governance & Business Services Linda Salley AML, OFAC & Fraud Director Governance
More informationMember States capabilities in fighting tax crimes
Latvia Tax avoidance is understood as a legal act - unless deemed illegal by the tax authorities or, ultimately, by the courts - of using tax regimes to one's own advantage to reduce one's tax burden.
More informationThe Role of Financial Information Sharing Partnerships in the Disruption of Crime. Infographic research summary
The Role of Financial Information Sharing Partnerships in the Disruption of Crime Infographic research summary The Future of Financial Intelligence Sharing (FFIS) programme leads independent research into
More informationCUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY
CUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY MCB SRI LANKA OPERATIONS 2017 Version 2.0 For Internal Use Only Document Control Sheet Title Of
More information