The Practical Impact of the FATF Mutual Evaluation on the US AML Professional
|
|
- Posy Foster
- 5 years ago
- Views:
Transcription
1 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 Task Force (FATF) Speakers: Nick Burbidge, Senior Advisor, AML/CFT Initiatives, Office of the Superintendent of Financial Institutions (OSFI) William J. Fox, Global Financial Crimes Compliance Executive, Bank of America Sarah Runge, Director, Office of Strategic Policy Terrorist Financing and Financial Crimes, US Department of the Treasury
2 Key Findings of the Evaluation The AML / CFT framework in the United States is well developed and robust. Domestic coordination and cooperation in AML / CTF issues is sophisticated. Understanding of money laundering and terrorist financing risks is well supported by risk assessment processes. The financial sector bears most of the burden related to required measures under the Bank Secrecy Act. Financial institutions have an evolved understanding of ML / TF risks and obligations, and have systems and processes for implementing preventative measures. The U.S. regulatory framework has some significant gaps, including minimal coverage of certain institutions and businesses (e.g., investment advisors; lawyers; accountants; real estate agents; trust and corporate service providers. Minimal measures are imposed on designated non-financial businesses and professions (DNFBPs), other than casinos and dealers in precious metals and stones. Lack of timely access to adequate, accurate and current beneficial ownership information remains one of the fundamental gaps in the U.S. AML / CTF regime. AML / CFT supervision of banking and securities sectors appears to be robust as a whole, and is evolving for money service businesses. The U.S. has a range of sanctions it can and does impose, which seem to have desired effect. 2
3 Key Findings of the Evaluation (continued) Law enforcement in the U.S. rests on a well-established task force environment, which enables pooling of expertise from a wide range of agencies. Law enforcement has access to a wide range of financial intelligence. There is a strong focus on following the money in predicate offense investigations. The U.S. investigates and prosecutes terrorist finance networks aggressively and in line with its risk profile. International cooperation is generally effective. At the Federal level, the U.S. annually prosecutes on average 1,200 money laundering cases. Many are large, complex, white collar crimes cases in line with the country s risk profile. Federal authorities have the lead role in all large and/or international investigations. There is no uniform approach to State-level AML efforts and it is not clear that all States give money laundering due priority. The U.S. would benefit from ensuring that a range of tax crimes are predicate offenses for money laundering. Federal authorities aggressively pursue high-value asset seizures in large and complex cases. The authorities effectively resort to criminal, civil and administrative tools to forfeit assets. U.S. authorities effectively implement and administer targeted economic sanctions for terrorism and proliferation purposes. The U.S. economic sanctions lists are used by Financial Institutions across the U.S. and beyond, which gives the U.S. sanctions regime a global effect. 3
4 In terms of overall effectiveness, the evaluation found that The United States achieves high results in prevention, investigation, prosecution and sanctions for terrorist financing and proliferation finance; for prevention of the abuse of the NGO sector, and for asset seizure. The United States achieves substantial outcomes in understanding money laundering and terrorist financing threats; domestic and international cooperation; using financial intelligence and other information; and investigating and sanctioning money laundering offenses, such that only moderate improvement is needed. The United States needs to make fundamental improvements in order to protect legal entities, and to a lesser extent legal arrangements, from money laundering or terrorist financing abuse and ensure competent authorities have timely access to beneficial ownership information. Major improvements are needed to apply appropriate preventative measures to all financial institutions and designated nonfinancial businesses and providers; and, to undertake effective supervision of all sectors. The United States supervisory regime for financial institutions is very complex, with AML / CFT supervision being taken by multiple regulators a the Federal and State level. The designated non-financial business and providers sectors are not well covered. Measures taken to prevent abuse of legal entities are inadequate, and the U.S. legal framework has serious gaps that must be addressed, particularly related to beneficial ownership. 4
5 Relating to Financial Institutions, the evaluation found that The United States has an extremely large and diverse financial and designated nonfinancial business and provider sectors. The financial sector bears most of the burden of preventative measures and reporting, with the domestic banking sector playing a predominant role in the domestic and international financial sectors, along with the securities sector. Money Service Businesses are large in number, diverse and also and important part of the financial architecture. Financial Institutions generally demonstrate a fair understanding of money laundering and terrorist financing risks and obligations, though the quality of understanding varies across and within sectors. The level of highest understanding is the banking sector. Residential Mortgage Lenders and Originators do not seem to have a good understanding of money laundering vulnerabilities in their sector. There are certain exemptions and thresholds in the BSA regime, non-coverage of all Investment Advisors for example, which generally soften the deterrent value of preventative measures being applied by Financial Institutions. Among designated non-financial businesses and providers, the casino sector is large and been identified as vulnerable to money laundering. In practice, while not essential, lawyers, company formation agents and, to a lesser extent, accountants are often involved with related transactions. While there is evidence that casinos have developed a greater appreciation for money laundering and terrorist financing issues, there is no evidence that the rest of the sectors have a clear understanding of vulnerabilities relating to money laundering and terrorist financing. 5
6 The mutual evaluation prioritized six (6) actions for the United States: 1. Take steps to ensure that adequate, accurate and current beneficial ownership information of U.S. legal entities is available to competent authorities in a timely manner, by requiring that such information be obtained at the Federal level. 2. Implement beneficial ownership requirements under the BSA and apply these to the sectors discussed in number 3 below. 3. Apply appropriate AML / CTF obligations to: a. Investment Advisors; b. On the basis of a vulnerability analysis, to lawyers, accountants, trust and company service providers (other than trust companies that are already covered); and, c. After outcomes of the current GTO are analyzed, take appropriate action to address the money laundering risks associated with high-end real estate. 4. Issue guidance to clarify the scope of the immediate SAR reporting requirement, in order to make it clear that the requirement applies below the otherwise applicable thresholds; and, conduct a focused risk review of the existing SAR reporting thresholds and the 60/30 day reporting requirements. 5. Improve the visibility of AML and State level activities and statistics, including improved data collection and sharing, for a clearer nation-wide picture of the adequacy of AML efforts at all levels. 6. FinCEN should continue to expand the use of tools such as the GTO and 314(a) requests, and further its proactive dissemination of strategic and operational intelligence to law enforcement. 6
7 Key Takeaways 1. The results of FATF Mutual Evaluation Reports have a direct bearing on national regulation. 2. Deficiencies identified in FATF reports are expected to be rectified within a reasonable timeframe and regular follow-up reports are done to monitor progress. This will be done in the US case. 3. The US report identifies inadequacies in the beneficial ownership and the broader transparency requirements and this will continue to be a particular focus in the follow-up reports. 4. For financial sector supervision including DNFBPs the report indicated: "There is a need for more and ongoing guidance from supervisors to industry on their regulatory expectations." 7
SUMMARY 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 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 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 informationPNG s Anti-Money Laundering & Counter Terrorist Financing Framework
PNG s Anti-Money Laundering & Counter Terrorist Financing Framework Wilson Onea Deputy Director Financial Analysis and Supervision Unit (FASU) PNG s Financial Intelligence Unit (FIU) Presentation Outline
More informationInternational Monetary Fund Washington, D.C.
2011 International Monetary Fund September 2011 IMF Country Report No. 11/267 Kuwait: Report on Observance of Standards and Codes FATF Recommendations for Anti-Money Laundering and Combating the Financing
More informationAustria. Follow-up report. Anti-money laundering and counter-terrorist financing measures
Anti-money laundering and counter-terrorist financing measures Austria 1st Enhanced Follow-up Report & Technical Compliance Re-Rating Follow-up report December 2017 The Financial Action Task Force (FATF)
More informationINTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE FINANCING OF TERRORISM & PROLIFERATION. The FATF Recommendations
INTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE FINANCING OF TERRORISM & PROLIFERATION The FATF Recommendations February 2012 INTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE
More informationINTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE FINANCING OF TERRORISM & PROLIFERATION. The FATF Recommendations
INTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE FINANCING OF TERRORISM & PROLIFERATION The FATF Recommendations Updated November 2017 FINANCIAL ACTION TASK FORCE The Financial Action Task
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 informationFATF & Real Estate. Carolyn E. Vick Vick Consulting Group March 2017
FATF & Real Estate Carolyn E. Vick Vick Consulting Group March 2017 1 1 FATF Mutual Evaluation of the US On December 1, 2016, the Financial Action Task Force (FATF - a global organization that evaluates
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 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 informationDeveloped by the APG Implementation Issues Working Group (IIWG) and the World Bank
Strategic Implementation Planning (SIP) Framework An implementation tool to prioritise your Mutual Evaluation Report/Detailed Assessment Report recommendations Developed by the APG Implementation Issues
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 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 informationHungary. Fifth Round Mutual Evaluation Report. Executive Summary. Key Findings
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM (MONEYVAL) Hungary MONEYVAL(2016)13 SUMM Fifth Round Mutual Evaluation Report Executive Summary This
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 informationInternational Standards on Combating Money Laundering and the Financing of. The FATF Recommendations
International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation The FATF Recommendations February 2012 INTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE
More informationPractical Suggestions for an Effective AML/OFAC Compliance Function
Practical Suggestions for an Effective AML/OFAC Compliance Function Institute of International Bankers 2013 Annual Anti-Money Laundering Seminar Paul S. Pilecki May 7, 2013 2013 Kilpatrick Townsend Recent
More informationImproving Global AML/CFT Compliance: Ongoing Process - 19 October 2018
別紙 2-1 Improving Global AML/CFT Compliance: Ongoing Process - 19 October 2018 Paris, France, 19 October 2018 - As part of its ongoing review of compliance with the AML/CFT standards, the FATF identifies
More informationMutual Evaluation Report. Anti money laundering and counter terrorist financing measures in Samoa 2015
` Anti money laundering and counter terrorist financing measures Samoa Mutual Evaluation Report September 2015 Anti money laundering and counter terrorist financing measures in Samoa 2015 The Asia/Pacific
More informationFinancial Inclusion and De-Risking : Navigating the Global Challenges
Financial Inclusion and De-Risking : Navigating the Global Challenges Monday, April 3 11:05 AM Moderator: Kieran Beer, CAMS, Editor-in Chief, ACAMS moneylaundering.com Speakers: Emile Van Der Does De Willebois,
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 informationExecutive Summary. Key Findings
EXECUTIV E SUMMARY Executive Summary 1. This report provides a summary of the AML/CFT measures in place in Mexico as at the date of the on-site visit (28 February to 16 March 2017). It analyses the level
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 informationJERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR FATF REVISED 40 RECOMMENDATIONS
JERSEY FINANCIAL SERVICES COMMISSION 5 TH ANNIVERSARY SEMINAR 1. Introduction 1.0 The FATF Forty Recommendations have been revised and these revised Recommendations are with immediate effect the new international
More informationMONEY LAUNDERING - The EU and Malta
MONEY LAUNDERING - The EU and Malta Author: George Farrugia α Background The new Prevention of Money Laundering Regulations 2003, which have just been published in August, implement the second European
More informationHighlights New AML/CFT Legislation. George Croes Senior Policy Advisor Integrity and
Highlights New AML/CFT Legislation George Croes Senior Policy Advisor Integrity and International ti laffairs 1 Contents presentation I. FATF - General II. III. IV. 40 + 9 FATF Recommendations Third FATF
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 informationINTER-GOVERNMENTAL ACTION GROUP AGAINST MONEY LAUNDERING IN WEST AFRICA. Second Follow Up Report. Mutual Evaluation SIERRA LEONE
INTER-GOVERNMENTAL ACTION GROUP AGAINST MONEY LAUNDERING IN WEST AFRICA Second Follow Up Report Mutual Evaluation SIERRA LEONE MAY 2009 2014 GIABA. All rights reserved. No reproduction or translation of
More informationImproving Global AML/CFT Compliance: On-going Process - 3 November 2017
Improving Global AML/CFT Compliance: On-going Process - 3 November 2017 Buenos Aires, Argentina, 3 November 2017 - As part of its on-going review of compliance with the AML/CFT standards, the FATF identifies
More informationINTER-GOVERNMENTAL ACTION GROUP AGAINST MONEY LAUNDERING IN WEST AFRICA. Fifth Follow Up Report. Mutual Evaluation
INTER-GOVERNMENTAL ACTION GROUP AGAINST MONEY LAUNDERING IN WEST AFRICA Fifth Follow Up Report Mutual Evaluation THE GAMBIA NOVEMBER 2012 2014 GIABA. All rights reserved. No reproduction or translation
More informationTECHNICAL PAPER: Guidance on the National Risk Assessment of Terrorist Financing in the Republic of Serbia
Project against Money Laundering and Terrorist Financing in Serbia MOLI Serbia DGI (2014) 28 February 2014 TECHNICAL PAPER: Guidance on the National Risk Assessment of Terrorist Financing in the Republic
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 informationDecember 14, Giancarlo Del Bufalo President Financial Action Task Force 2, rue Andre Pascal Paris France. Dear Mr.
December 14, 2011 Giancarlo Del Bufalo President Financial Action Task Force 2, rue Andre Pascal 75016 Paris France Dear Mr. Del Bufalo: On behalf of the members of the ICSA Working Group on AML, we would
More informationCountry Risk Updates. GFSC Newsletter No.3/2017.
Country Risk Updates GFSC www.gfsc.gi 27 November 2017 This newsletter constitutes advice issued by the (GFSC) about risks posed by unsatisfactory money laundering controls in a number of jurisdictions.
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 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 informationImproving Global AML/CFT Compliance: On-going Process - 24 February 2017
Improving Global AML/CFT Compliance: On-going Process - 24 February 2017 Paris, France, 24 February 2017 - As part of its on-going review of compliance with the AML/CFT standards, the FATF identifies the
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 informationCommuniqué 3 25 October 2018
Communiqué 3 25 October 2018 National Risk Assessment of Money Laundering and Terrorist Financing 1 Overview In October 2017, Jersey s Financial Crime Strategy Group issued a statement concerning the Island
More informationFIRST ROUND MUTUAL EVALUATIONS POST EVALUATION PROGRESS REPORT OF KENYA. Covering the period August 2017 July 2018
FIRST ROUND MUTUAL EVALUATIONS POST EVALUATION PROGRESS REPORT OF KENYA Covering the period August 2017 July 2018 ESAAMLG (2018), First Round Mutual Evaluation Post Evaluation Progress Report of Kenya
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 informationHow are legal arrangements (express trusts and trust-like agreements) formed in the United States?
USA Response: Collection of Information Regarding Implementation of Resolution 7/2 of the Conference of States Parties to the UN Convention against Corruption In response to the Secretariat s request for
More informationCorrespondent Banking and De- Risking. Hans-Peter Bauer Stockholm October 5 th 2017
Correspondent Banking and De- Risking Hans-Peter Bauer Stockholm October 5 th 2017 De-Risking and Correspondent Banking Taking and transferring risk is the core of banking Banks have increased and decreased
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 informationEva Rossidou Papakyriacou Senior Counsel of the Republic Head of the Unit for Combating Money Laundering (MOKAS)
Eva Rossidou Papakyriacou Senior Counsel of the Republic Head of the Unit for Combating Money Laundering (MOKAS) The process by which criminals conceal the true origin and ownership of the proceeds of
More informationAML CFT STANDARDS. In theory and practice. Combatting Restrictions On Civic Freedoms Arising From Counter -terrorism & Anti-money Laundering Rules
Combatting Restrictions On Civic Freedoms Arising From Counter-terrorism & Anti-money Laundering Rules AML CFT STANDARDS In theory and practice The global standard setter for anti money laundering and
More informationSerbia. Fifth Round Mutual Evaluation Report. Executive Summary. Key Findings
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM (MONEYVAL) Serbia MONEYVAL(2016)2 SUMM Fifth Round Mutual Evaluation Report Executive Summary This
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 informationTHE ASSESSMENT OF BERMUDA S NATIONAL MONEY LAUNDERING AND TERRORIST FINANCING RISK. Report
THE ASSESSMENT OF BERMUDA S NATIONAL MONEY LAUNDERING AND TERRORIST FINANCING RISK Report Table of Contents Foreword... 4 Executive Summary... 5 Chapter 1: Introduction and Context... 7 Relevant FATF requirements...
More informationEUROPEAN COMMISSION DG Migration and Home affairs DG Justice and Consumers. Methodology
EUROPEAN COMMISSION DG Migration and Home affairs DG Justice and Consumers Approved at ISG AML/CFT Date: 04.11.2015 Version 1.1 Methodology for assessing money laundering and terrorist financing risks
More informationFinancial Action Task Force. Groupe d'action financière
Financial Action Task Force Groupe d'action financière SUMMARY OF THE THIRD MUTUAL EVALUATION REPORT ON ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM UNITED STATES OF AMERICA 23 JUNE 2006
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 informationEffective Regimes to Combat Money Laundering and the Financing of Terrorism Strengthening the Collaborative Process.
Effective Regimes to Combat Money Laundering and the Financing of Terrorism Strengthening the Collaborative Process Lessons Learned i Copyright 2004 The International Bank for Reconstruction and Development.
More informationZIMBABWE NATIONAL ANTI-MONEY LAUNDERING AND COMBATING FINANCING OF TERRORISM STRATEGIC PLAN FOR THE PERIOD:
ZIMBABWE NATIONAL ANTI-MONEY LAUNDERING AND COMBATING FINANCING OF TERRORISM STRATEGIC PLAN FOR THE PERIOD: 2015-2018 JUNE 2015 1 P a g e Table of Contents INTRODUCTION... 3 VISION STATEMENT... 3 MISSION
More informationCONSULTATION PAPER NO.118 PROPOSED CHANGES TO THE DFSA S ANTI MONEY LAUNDERING, COUNTER- TERRORIST FINANCING AND SANCTIONS REGIME
CONSULTATION PAPER NO.118 PROPOSED CHANGES TO THE DFSA S ANTI MONEY LAUNDERING, COUNTER- TERRORIST FINANCING AND SANCTIONS REGIME 22 FEBRUARY 2018 PREFACE CHANGES TO THE DFSA S AML REGIME Why are we issuing
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 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 informationREPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL
EUROPEAN COMMISSION Brussels, 11.4.2012 COM(2012) 168 final REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the application of Directive 2005/60/EC on the prevention of the use
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 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 informationA PRESENTATION AT THE 4 TH ANNUAL INSITUTE OF CERTIFIED PUBLIC ACCOUNTANTS OF KENYA (ICPAK) FINANCIAL CONFERNCE HILTON HOTEL, NAIROBI
A PRESENTATION AT THE 4 TH ANNUAL INSITUTE OF CERTIFIED PUBLIC ACCOUNTANTS OF KENYA (ICPAK) FINANCIAL CONFERNCE HILTON HOTEL, NAIROBI BY CNTRAL BANK OF KENYA o Introduction? o Vulnerability of Accountants
More informationTo Follow that SAR: Suspicious Activity Reports from Red Flags to Verdict
To Follow that SAR: Suspicious Activity Reports from Red Flags to Verdict Wednesday, April 5 8:50 AM Moderator: Dennis M. Lormel, CAMS, President and Chief Executive Officer, DML Associates Speakers: James
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 informationFinancial inclusion and financial integrity Challenges and opportunities
FINANCIAL ACTION TASK FORCE GROUPE D ACTION FINANCIÈRE Financial inclusion and financial integrity Challenges and opportunities UPU Global Forum on Financial inclusion for Development, 24 October 2013
More informationAppendix 2. In this Appendix underlining indicates new text and striking through indicates deleted text. The DFSA Rulebook
Appendix 2 In this Appendix underlining indicates new text and striking through indicates deleted text. The DFSA Rulebook Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML) 1
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 informationSECRETARIAT NOTE. 2. This note also presents a brief summary of progress made by Brunei Darussalam since July 2012.
SECRETARIAT NOTE Purpose 1. In accordance with APG members decision at the 2013 Annual Meeting that Brunei Darussalam move from regular to biennial reporting on the basis of the findings of the 2012 APG
More informationInternational Monetary Fund s Financial Sector Stability Assessment. Force Report
International Monetary Fund s Financial Sector Stability Assessment and Caribbean Financial Task Force Report Cherno Jallow,QC Director, Policy, Research and Statistics Meet The Regulator 16 March 2011
More informationThailand recent initiatives in AML/CFT. Mr. Weekoon Nithimutrakul Director, Financial Intelligence Division AMLO (ANTI-MONEY LAUNDERING OFFICE)
Thailand recent initiatives in AML/CFT Mr. Weekoon Nithimutrakul Director, Financial Intelligence Division AMLO (ANTI-MONEY LAUNDERING OFFICE) 1 Hit the criminals where they hurt the most Their pocket
More informationCongressional Testimony
Congressional Testimony Evaluating the Security of the U.S. Financial Sector Chip Poncy Senior Advisor, Center on Sanctions and Illicit Finance (CSIF), Founding Partner, Financial Integrity Network House
More informationFinancial Action Task Force Groupe d'action financière
Financial Action Task Force Groupe d'action financière SUMMARY OF THE THIRD MUTUAL EVALUATION REPORT ON ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM HONG KONG, CHINA 20 JUNE 2008 FATF/OECD
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 informationAML/CTF Efforts and Forecasts for Ireland. 23 February 2017
AML/CTF Efforts and Forecasts for Ireland 23 February 2017 Welcome Sheila Duignan Partner, Business Risk Services, Grant Thornton Agenda 7.00pm Welcome Sheila Duignan, Grant Thornton 7.05pm Guest Speaker
More informationREPORT ON THE OBSERVANCE OF STANDARDS AND CODES FATF RECOMMENDATIONS FOR ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM (AML/CFT)
IMF Country Report No. 16/44 February 2016 ITALY REPORT ON THE OBSERVANCE OF STANDARDS AND CODES FATF RECOMMENDATIONS FOR ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM (AML/CFT) This Report
More informationJapan Financial Intelligence Center (JAFIC) Annual Report
Japan Financial Intelligence Center (JAFIC) Annual Report 2016 JAFIC: Japan Financial Intelligence Center Introduction It has been 10 years since the enactment of the Act on Prevention of Transfer of Criminal
More informationRELIANCE ON THIRD PARTIES
Jefferson JL CLARKE Law Enforcement Advisor CFATF Secretariat May 8, 2015 1. Recommendation 17 2. Regulated, Supervised and Monitored 3. Reliance vs Outsourcing BASIS FOR RELIANCE Financial institutions
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 informationSuriname. November, 2015
Post-Plenary final CARIBBEAN FINANCIAL ACTION TASK FORCE Eight Follow-Up Report Suriname November, 2015 2015 CFATF. All rights reserved. No reproduction or translation of this publication may be made without
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 informationMONTENEGRO. Report on Fourth Assessment Visit Executive Summary. Anti-Money Laundering and Combating the Financing of Terrorism
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM (MONEYVAL) MONEYVAL(2015)12 SUMM Report on Fourth Assessment Visit Executive Summary Anti-Money Laundering
More informationAssessment of international and domestic risks of money laundering and terrorist financing affecting Scottish solicitors (May 2017)
1 Law Society of Scotland Assessment of international and domestic risks of money laundering and terrorist financing affecting Scottish solicitors (May 2017) 2 Index Introduction 3 Overall Conclusion 4
More informationTo whom it may concern. Implementation of the 4th EU Anti Money Laundering Directive
To whom it may concern Executive Office/ Legal and International Affairs Contact: Philipp Röser Phone: +423 236 62 37 E-Mail: philipp.roeser@fma-li.li Vaduz, January 18, 2018 AZ: 7404 Implementation of
More informationMethodology FOR ASSESSING TECHNICAL COMPLIANCE WITH THE FATF RECOMMENDATIONS AND THE EFFECTIVENESS OF AML/CFT SYSTEMS
Methodology FOR ASSESSING TECHNICAL COMPLIANCE WITH THE FATF RECOMMENDATIONS AND THE EFFECTIVENESS OF AML/CFT SYSTEMS Updated November 2017 FINANCIAL ACTION TASK FORCE The Financial Action Task Force (FATF)
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 informationIreland: Report on the Observance of Standards and Codes FATF Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism
February 2007 IMF Country Report No. 07/78 Ireland: Report on the Observance of Standards and Codes FATF Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism This Report on
More informationwww2.acams.org/webinars
COPYRIGHT NOTICE USE OF WEBEX LOGIN/PASSWORD FOR ACAMS WEB SEMINARS Each site license entitles registrant to one login: one phone connection (if accessing audio via teleconference) and one Internet connection
More informationESTONIA. Report on Fourth Assessment Visit Executive Summary. Anti-Money Laundering and Combating the Financing of Terrorism
COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM (MONEYVAL) MONEYVAL(2014)20 SUMM Report on Fourth Assessment Visit Executive Summary Anti-Money Laundering
More informationIntroduction to FATF THE FINANCIAL ACTION TASK FORCE AND THE ROLE OF LAWYERS IN COMBATING MONEY LAUNDERING AND TERRORIST FINANCING
THE FINANCIAL ACTION TASK FORCE AND THE ROLE OF LAWYERS IN COMBATING MONEY LAUNDERING AND TERRORIST FINANCING PRACTICING LAW INSTITUTE INTERNATIONAL ESTATE & TAX PLANNING 2018 MAY 21, 2018 Presented by
More informationThe National Anti-Money Laundering Committee and the Bermuda Monetary Authority
The National Anti-Money Laundering Committee and the Bermuda Monetary Authority CONSULTATION PAPER Proposed Legislative Amendments Anti-Money Laundering Legislation and Financial Institutions February
More informationSuriname. May, Seventh Follow-Up Report. Post-Plenary-Final CARIBBEAN FINANCIAL ACTION TASK FORCE
CARIBBEAN FINANCIAL ACTION TASK FORCE Seventh Follow-Up Report Suriname May, 2015 2015 CFATF. All rights reserved. No reproduction or translation of this publication may be made without prior written permission.
More informationThe Republic of Yemen On Anti-Money Laundering and Combating Financing of Terrorism
Middle East and North Africa Financial Action Task Force Executive Summary of the Mutual Evaluation Report Of The Republic of Yemen On Anti-Money Laundering and Combating Financing of Terrorism This Executive
More informationFEBRUARY 2013 / 811 FOR THE NZ LEGAL PROFESSION ANTI-M NEY. LAUndering AND COUNTERING FINANCING OF TERRORISM ~ PAGE 4 ~
LAWTALK 1 FEBRUARY 2013 / 811 FOR THE NZ LEGAL PROFESSION ANTI-M NEY LAUndering AND COUNTERING FINANCING OF TERRORISM ~ PAGE 4 ~ 1 LAWTALK 811 / 1 FEBRUARY 2013 4 LAWTALK 811 / 1 FEBRUARY 2013 ~ FEATURE
More informationHigh-risk and non-cooperative jurisdictions
High-risk and non-cooperative jurisdictions FATF PUBLIC STATEMENT - 19 October 2012 Paris, 19 October 2012 - The Financial Action Task Force (FATF) is the global standard setting body for antimoney laundering
More informationF o l l o w Up R e p o r t. Anti-money laundering and counter-terrorist financing measures. Ethiopia
F o l l o w Up R e p o r t Anti-money laundering and counter-terrorist financing measures Ethiopia 5 th Enhanced Follow Up Report and Technical Compliance Re-Rating September 2018 Ethiopia: 5 th Enhanced
More informationReviewing Canada s Anti-Money Laundering and Anti-Terrorist Financing Regime Summary, Analysis and Discussion Points. Matt McGuire
Reviewing Canada s Anti-Money Laundering and Anti-Terrorist Financing Regime Summary, Analysis and Discussion Points Matt McGuire The Review 2 1. Reviewing Canada s Anti-Money Laundering and Anti-Terrorist
More informationFinancial Action Task Force Groupe d'action financière
Financial Action Task Force Groupe d'action financière SUMMARY OF THE THIRD MUTUAL EVALUATION REPORT ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM ICELAND October 2006 Executive Summary
More informationMoney Laundering in the Trinidad & Tobago Securities Sector
Money Laundering in the Trinidad & Tobago Securities Sector J A N U A R Y 7, 2 0 1 5 M A R K E T S E S S I O N - A M L - C F T - T H E M O N E Y, T H E L A W A N D Y O U T R I N I D A D H I L T O N H O
More informationRegulatory Impact Statement: Second phase of reforms to the Anti-Money Laundering and Countering Financing of Terrorism regime
Regulatory Impact Statement: Second phase of reforms to the Anti-Money Laundering and Countering Financing of Terrorism regime Agency Disclosure Statement 1. This Regulatory Impact Statement (RIS) has
More information