Palestine Anti -Money Laundering Accreditation PAMLA

Transcription

1 Palestine Anti -Money Laundering Accreditation PAMLA

2 Main Objectives To educate the student on what constitutes money laundering and its history To illustrate the adverse effects that money laundering/terrorist financing have on economies and the financial sector. To highlight the importance of anti-money laundering/terrorist financing efforts in Palestine or any Target country. To describe international and local efforts to combat money laundering/terrorist financing. To provide guidance in compliance requirements for AML/CFT under international standards and Palestinian law. To demonstrate the inter-relationship between AML/CFT efforts and overall best practices for financial institutions To inform the student as to commonly identified indicators which may be suggestive of money laundering and other crime To describe to the student, the role of various international and governmental organizations and agencies in the fight against money laundering/terrorist Financing. To have the student apply the information obtained in this course to selected examples of money laundering/terrorist financing. To provide to the student basic awareness, knowledge and skills as to the nature of money laundering and what can be done to prevent money laundering so that the student can apply those skills in helping their financial sector comply with internationally accepted financial standards. Phase I: General AML awareness I. Introduction to Money Laundering / terrorist financing. a. What is money laundering? i. 3 phases of money laundering ii. Some examples b. History of money laundering i. Case examples ii. Legal efforts c. What is terrorist financing? II. Phases of terrorist financing. III. Some examples. a. Effects of money laundering/terrorist financing on economies and institutions i. Types of risks 1. Legal and compliance risks 2. Reputational risks 3. Operational risks 4. Concentration Risks ii. Sectors facing impact of risks 1. Institutional 5. Political 2. Social 6. Individual/Consumer 3. Reputational 4. Economic Comply with international and local compliance requirements; PIFBS, FFU-PMA and MFI introduce especial training course (PAMLA; Palestine Anti -Money Laundering accreditation )

3 IV. Efforts to Combat Money Laundering /Terrorist financing a. FATF and other international initiatives i. What is the FATF? ii. Why the FATF became involved in AML/CFT iii. Revised 40 Recommendations 1. AML vs. CFT iv. IMF v. World Bank vi. UNODC b. Regional AML/CFT efforts i. MENA FATF ii. Asia Pacific (APGML) iii. MONEYVAL (European Commission) iv. Other regional organizations c. Foreign Jurisdiction efforts (Europe, USA, etc.) i. USA Patriot Act ii. Europe Directives d. Efforts of financial institutions i. Wolfsburg Group e. Specialized International Organizations i. Basel Banking ii. IOSCO Insurance f. General overview of Palestinian regulatory regime i. Law and regulations ii. National AML Committee iii. Financial Follow-Up Unit (FFU) Phase II: I. Details of Palestinian regulatory regime i. AML/CFT Law ii. National AML Committee iii. Financial Follow-Up Unit (FFU) and its role iv. Palestine Monetary Authority (PMA)-CENTRAL Bank Role. v. Palestine Capital Markets Authority (PCMA)

4 II. Compliance Requirements a. Essential components of AML compliance b. Internal policy/kyc c. Designation of compliance staff d. Monitoring and recordkeeping e. Reporting to authorities where required f. Training of staff g. Internal audit III. How to Detect Money Laundering/terrorist financing? a. Types of Activities that are vulnerable to money laundering/terrorist financing. b. Financial sector and industry specific threats c. Red-flag indicators d. What to do when suspicion indicates possible money laundering IV. Anti-Money Laundering/terrorist financing Efforts in Palestine a. AML law in Palestine b. Role of Financial Follow-Up Unit V. Related issues to AML a. Prevention of predicate offences fraud, corruption and other crime VI. Case Studies Phase III: I. National Compliance Concerns a. FATF and other International Recommendations i. Go over specific recommendations and how they apply in industry specific instances in Palestine b. 40 Recommendations c. IMF and World Bank roles d. Mutual evaluations by regional bodies II. Institutional Compliance Concerns/Industry Specific Concerns a. Establishing a culture of compliance within the institution i. Adopting Company AML/CFT policy at the directors level ii. Building and Implementing the policy and legal requirements into an effective AML program for the institution and staff iii. Selection and qualifications of compliance staff/duties and responsibilities iv. Training programs what and how to implement

5 b. Know Your Customer and Enhanced Due Diligence i. Customer identification ii. Customer acceptance policy iii. Expected Financial Profile iv, Customer verification and updates v. Politically Exposed Persons and special cases vi. Monitoring for deviations from the expected profiles c. Risk Management i. Risk based approach 1. Customer base (i.e. type of business activity, etc.) 2. Products 3. Geographic 4. Type and mode of transaction ii. Collateral benefits of risk management d. Identification of Reportable Cases i. Methodology ii. Software and databases e. Monitoring of accounts and transactions f. Writing a report to the FFU i. Suspicious Transaction or Activity Reports 1. Forms 2. How to Write Reports 3. Where and how to submit reports ii. Cash Transaction Reports iii. Wire Transaction Reports iv. Follow-up Reports III. Case Studies a. How to identify indicators b. How to write reports c. How to conduct monitoring and follow-up investigations? PAMLA Time Table. See the following Page

6 PAMLA Time Table Thursday Wednesday Tuesday Monday Sunday Saturday (9:00-17:00) (9:00-17:00) During August (13:00-18:00) 19 (9:00-18:00)