DFSA Annual Supervision Outreach Breakout Group # 3 Financial Crime Risks. 25 June 2018
|
|
- Joel Chambers
- 5 years ago
- Views:
Transcription
1 DFSA Annual Supervision Outreach Breakout Group # 3 Financial Crime Risks 25 June 2018
2 Breakout Group 3 - Agenda Opening Comments - Lawrence Paramasivam Director, Supervision General updates from the Financial Crime Team - Sara M. Bin Kalban Associate Director, Supervision Update from Policy in relation to CP118 & CP Elisabeth Wallace Senior Manager, Policy & Strategy Market Abuse - Wael El-Nagar Senior Manager, Markets Annual AML Return 2017 Findings - Sean Higgins Senior Manager, Supervision Closing remarks - Sara M. Bin Kalban Associate Director, Supervision
3 General Updates From The Financial Crime Team Sara M. Bin Kalban Associate Director, Supervision
4 Financial Crime Priorities 2018/2019 Preparation for the upcoming FATF Mutual Evaluation in 2019 Risk Based Supervision of Authorised Firms and DNFBPs annual AML Return AML focused risk assessments sectoral reviews Implementation of AML Rule Changes Sanctions compliance FATCA & CRS reporting through the DIFC Registrar of Companies
5 Overview of the FATF Mutual Evaluation Process The FATF Mutual Evaluation will be based on the FATF 40 Recommendations of 2012 and The Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of the AML/CFT System of The FATF 40 Recommendations of 2012 have seven themes: AML/CFT Policies and Coordination Money Laundering and Confiscation Terrorist Financing and Financing of Proliferation Preventive Measures Transparency and Beneficial Ownership of Legal Persons and Arrangements Powers and Responsibilities of Competent Authorities and Other Institutional Measures International Cooperation
6 FATF 2013 Methodology The FATF 2013 Methodology is used for assessing technical compliance with the FATF Recommendations and the effectiveness of AML/CFT systems and controls. It stems from the high level objective which is Financial systems and the broader economy are protected from the threats of money laundering and the financing of terrorism and proliferation, thereby strengthening financial sector integrity and contributing to safety and security. Technical Compliance Focus on implementation of FATF recommendations in terms of laws, regulations and powers/procedures of institutions. A five scale rating systems being: Compliant (C), Largely Compliant (LC), Partially Compliant (PC); Non-Compliant (NC); and Not Applicable Effectiveness Assessment On-site assessment focussing on 11 immediate outcomes which focus on results. It affects multiple competent authorities and private sector. It involves substantial complex analysis. A four scale system being: High Effectiveness (HE), Substantial Effectiveness (SE), Moderate Effectiveness (ME); and Low Effectiveness (LE)
7 FATF Preparation Process The UAE will be subject to joint FATF-MENAFATF Mutual Evaluation in June/July In Mid-2017, the UAE s National Anti-Money Laundering and Combating Financing of Terrorism Committee (NAMLCFTC) has engaged a team of AML/CFT Experts to assist in the preparation process. As per the provided mandate, the Experts Team will be providing legal, technical and all other relevant assistance in preparation for the Mutual Evaluation.
8 Schedule and preparation of the UAE Preparation with the Expert Team commenced in September The UAE (including the DIFC) is currently working on three key work streams being: National Risk Assessment Technical Compliance self-assessment Effectiveness Compliance self-assessment The submission to the FATF-MENAFATF Assessors will be as follows: Technical Compliance questionnaire & National Risk Assessment: Q Effectiveness questionnaire: early Q Discussion of Mutual Evaluation Report at the Plenary is expected to take place in 2020.
9 Update from Policy in Relation to Recent AML Consultation Papers Elisabeth Wallace Senior Manager, Policy and Strategy
10 Consultation Paper 118 & Consultation Paper 120 CP 118 published in February and closed in March dealt with: clarifications of the DFSA s AML remit in the DIFC; and changes to deal with DFSA powers relating to DNFBPs CP 120 published in April and closed in May dealt with: changes to align our regime with FATF recommendations including: Customer Due Diligence (CDD) FATF Recommendation 10; Record Keeping FATF Recommendation 11; New Technologies FATF Recommendation 15; Wire transfers - FATF Recommendation 16; Reliance on third parties FATF Recommendation 17; Internal controls and foreign branches and subsidiaries FATF Recommendation 18; Higher risk countries FATF Recommendation 19; and Transparency and beneficial ownership of legal arrangements FATF Recommendation 25. Next steps changes to the Regulatory Law and AML Module to come into force in Q3 2018
11 Market Abuse Wael El-Nagar Senior Manager, Markets
12 DIFC Markets Law - Application The market abuse prohibitions are set out in DIFC Markets Law, Articles and they prohibit any person from engaging in of the activity noted under Art The market abuse prohibitions apply to: A person: an entity or an individual, regulated or not In the DIFC or elsewhere i.e. applies to a person that is physically located in another jurisdiction (provided it affects DIFC markets or users of DIFC markets) Directly or indirectly Investment, related investment
13 Therefore it follows that The Markets Law applies to Recognised Members and Authorised Firms in respect of conduct relating to Investments (not just those admitted to trading)
14 What is Market Abuse? 8 Provisions under the Markets Law 1. Fraud and market manipulation 2. False or misleading statements 3. Use of fictitious devices and other forms of deception 4. False or misleading conduct and distortion 5. Insider dealing 6. Providing Inside Information 7. Inducing Persons to deal 8. Misuse of information
15 Prohibitions against Market Abuse and Financial Crime GEN Rule requires an Authorised Person to establish and maintain systems and controls that ensure, as far as reasonably practical, that the Authorised Person and its employees do not engage in conduct, or facilitate others to engage in conduct, which may constitute market abuse, whether in the DIFC or elsewhere; or a financial crime under any applicable U.A.E. law:
16 Notification of Suspected Market Abuse GEN Rule A requires an AF to notify the DFSA immediately if it: receives an order from a client, or arranges or executes a transaction with or for a client; and has reasonable grounds to suspect that the order or transaction may constitute market abuse under Part 6 of the Markets Law The notification must specify: sufficient details of the order or transaction; and the reasons for the AF suspecting that the order or transaction may constitute market abuse
17 Notification of Suspected Market Abuse (cont d) An AF must not inform the client, or any other person involved in the order or transaction, of a notification under this Rule If an AF reasonably suspects that a client's order or transaction may constitute market abuse under the laws in another jurisdiction, it will also need to consider if it needs to notify the regulator in that other jurisdiction (under any corresponding obligation to notify). If an AF becomes aware that the firm itself, or an employee of the firm, (rather than a client) has engaged in conduct that may constitute market abuse in the DIFC or elsewhere, it has a separate obligation to notify the DFSA under Article 67 of the Regulatory Law and GEN Rule
18 Annual AML Return 2017 Findings Sean Higgins Senior Manager, Supervision
19 The Annual AML Return The DFSA is committed to combating money launderers, terrorist financiers and other financial criminals and is also committed to demonstrating effective compliance with the 40 Recommendations of the Financial Action Task Force. Bryan Stirewalt Managing Director Supervision DFSA Similarly, collecting better data and using that data efficiently is a key objective of the DFSA. The AML Return brings each of these objectives mentioned above together in our effort to gather data more efficiently and use that data is a way that helps us achieve compliance with global standards for combating financial crime.
20 The Annual AML Return Number of Returns submitted to the DFSA As the DIFC grows, we will continue to evolve this tool to allow us to assess Relevant Persons compliance with their AML/CFT and sanctions compliance.
21 Annual AML Return Structure There are a number of factors that are key differentiators in the highest performing compliance and AML programmes and these were included in the annual AML return structure. These are considered to be: Senior Management Governance Tone at the top Risk Assessments and Customer Due Diligence Reliance and Outsourcing Audit (applicable to Authorised Firms) Correspondent Banking (applicable to Authorised Firms) Sanctions and other international obligations AML training and awareness MLRO notifications and Suspicious Activities Reports
22 Presentation Overview The presentation will cover the findings of 5 main topics being: Senior Management Governance AML Business Risk Assessments Suspicious Activities and Transactions Audit (applicable to Authorised Firms) AML Training During the course of the presentation, we will have a number of survey questions related to the topics under discussion. In order to participate in the survey, you will need to download the DFSA app and access the survey link via the events page.
23 Topic 1 : Senior Management Governance The first ingredient of a world class compliance and AML programme is the right tone at the top. The tone at the top sets a firm s Board guiding values and ethical climate. It is the ethical glue that binds everything together.
24 Total Respondents 546 Senior Management Participation in AML: Findings From The AML Return The AML Return sought to understand how Senior Management carry out their AML responsibilities. The findings are as follows: Discuss AML at Board Meetings 78% Participate in AML compliance reviews 82% Participate in AML business risk assessments 90% Approve high-risk customers 68% 497 Approve policies and procedures 91% Approve high-risk transactions 46% Senior Management involvement is critical
25 Survey Question 1 Q: How are AML/CFT policies and controls communicated to senior management and staff? a Through AML training Through circulated directives or guidelines Through embedded compliance staff in business lines Through being integrated in the firm s dayto-day activities?
26 Topic 2: AML Business Risk Assessments Step 1 Identify your risks Step 6 Revisit your AML risks annually Step 5 Assess risk potential & impact AML Business Risk Assessment Process Step 4 Identify controls & reduce risks Step 2 Create your risk library Step 3 Identify your risk owners
27 Total Respondents 546 The AML Business Risk Assessment: Findings From The AML Return The AML Return sought to note the vulnerabilities that Relevant Persons take into account when identifying and assessing AML/CFT and sanctions risk. The findings are as follows: Type of customer & their activities 97% The countries or geographic areas in which it does business 98% Products, services & activity profile 94% Distribution channels & business partners 86% Complexity & volume of transactions The use of new or developing technologies for new/existing products 61% 84% Which of these returns should be at 100%? Development of new products & business practices 70% 70%
28 Key Message: AML Business Risk Assessments Keep your AML Business Risk Assessment (BRA) up to date. AML risks change over time; circumstances change, the firm changes and threats evolve. You should consider how your policies and procedures adapt to emerging risks, i.e. how do you stay up to date? Adopting an AML BRA can never eradicate all risks; the firm and your staff should exercise constant vigilance. Your AML BRA is a living document, ever changing with rules or guidelines for its modification.
29 Survey Question 2 Q: What is your biggest challenge in keeping your AML Business Risk Assessment robust? Difficulty in capturing and priortising relevant risks Difficulty in measuring risks Difficulty in getting a buy-in from senior management Difficulty in understanding regulatory expectations?
30 Topic 3:Suspicious Activities And Transactions Relevant Persons are part of an intelligence chain. The Federal AML Legislation and the DFSA Module requires Relevant Persons where there is a suspicion or reasonable grounds to suspect that funds are the proceeds of criminal activity, or are related to TF, to make a report to the Financial Intelligence Department. Transactions and attempt transactions, regardless of amount, must be reported as soon as practicable after reasonable grounds for suspicion are formed.
31 Suspicious Activities and Transactions: Findings From The AML Return Internal Notifications External Reporting 88% of Relevant Persons reported no internal suspicious transaction or activity notifications 90% of Relevant Persons did not file an SAR with the FID.
32 Suspicious Activities And Transactions: Findings From The AML Return Number of SARs lodged with FID versus notifications received by the DFSA Lodged an SAR with FID Submitted a notification to the DFSA Reminder: Relevant Persons are required to notify the DFSA following the submission of an SAR with the FID.
33 Survey Question 3 Q: What challenges are you facing filing SARs? Uncertain about criteria for filing Unsure how to file an SAR FID portal Limited or non existent staff notifications All of the above?
34 Topic 4: Audit Your firm s third line of defence for AML risk is provided by your internal audit. Tasked by, and reporting to the board / audit committee, it provides an evaluation, through an AML risk-based approach, on the effectiveness of governance, risk management, and internal control to your firm s senior management. It can also give assurance to sector regulators and external auditors that appropriate controls and processes are in place and are operating effectively.
35 Audit: Findings From The AML Return Total Respondents 546 The AML Return sought to capture the date an Authorised Firm s audit function last conduct a review of its AML policies, procedures, systems and controls. The findings are as follows: % % % % % Before % 3rd line of defence Stated scheduled for 2018 or left blank 25%
36 Topic 5: AML training AML training is a vital element in mitigating risk for a firm s exposure to money laundering, terrorist financing and meeting sanctions obligations. The DFSA requires under the AML Rulebook that Relevant Persons provide AML training to all relevant employees on regular intervals and as soon as reasonable practicable after commencing employment. It must be tailored to the relevant persons activities, including the firms products, services, Annually customers and channels. Whenever a significant event occurred. Rule change
37 AML Training: Findings From AML Return Total Respondents 546 When did the Relevant Person provide AML training to all relevant employees? Annually 86% As soon as reasonably practical following commencement of employment 82% Whenever a significant event occurred (e.g. Rule changes) 52%
38 Survey Question 4 Q: What challenges are you facing to meet the AML training needs of your firm? 1. The AML training is not specific to the particular business line of the firm 2. Staff availability 3. AML training is not at the same level as other financial crime training provided 4. Cost?
39 Annual AML Return: Key Take Away The 2017 annual AML Return was the first submission using the online forms system. Next year, the DFSA will have the opportunity for more comparable statistics and highlights. The results are reliant on the completeness of the response and the correctness of the information provided. Overall, the AML Return has identified good levels of overall adherence to regulatory obligations; however, there are key elements in the AML space that still need to be addressed. The DFSA will be focusing on this elements in its supervisory approach. In between times remember, people may hear your words, but will feel your attitude and see your actions. Lead by example.
40 QUESTIONS
41 Thank You
CONSULTATION 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 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 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 informationCONSULTATION PAPER NO.120
CONSULTATION PAPER NO.120 PROPOSED CHANGES TO THE DFSA S ANTI MONEY LAUNDERING, COUNTER- TERRORIST FINANCING AND SANCTIONS REGIME PHASE 2 18 APRIL 2018 PREFACE Why are we issuing this Consultation Paper
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 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 informationDFSA OUTREACH INTRODUCTORY PRESENTATION 4 June 2015
DFSA OUTREACH INTRODUCTORY PRESENTATION 4 June 2015 The Dubai Financial Services Authority (DFSA) in providing this DFSA outreach presentation to you for information purposes only. The DFSA does not make
More informationQUESTION & ANSWERS ANTI MONEY LAUNDERING, COUNTER-TERRORIST FINANCING, AND SANCTIONS REGIME
QUESTION & ANSWERS ANTI MONEY LAUNDERING, COUNTER-TERRORIST FINANCING, AND SANCTIONS REGIME Disclaimer: The questions and answers in this document are for general information purposes only, and are based
More informationFinancial Crime update. 12 September 2017
Financial Crime update 12 September 2017 1 GFSC Intro MONEYVAL overview by the National Coordinator Representative Update since March What s next Questions/Comments 22 September 2017 2 FSC Industry Outreach
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 informationAppendix 2. The text in this appendix is new and is not underlined and struck through in the usual manner. The DFSA Rulebook
Appendix 2 The text in this appendix is new and is not underlined and struck through in the usual manner. The DFSA Rulebook Designated Non-Financial Businesses and Professions Module (DNF) DESIGNATED Contents
More informationDFSA Annual Outreach Session. Monday, 25 June 2018
DFSA Annual Outreach Session Monday, 25 June 2018 Key Note Speech Bryan Stirewalt Managing Director, Supervision Upcoming Event for your Calendars 12 July 2018 Visit from Ms. Sigal Mandelker, US Under
More informationSlovenia. Anti-money laundering and counter-terrorist financing measures. F o l l o w - u p r e p o r t
F o l l o w - u p r e p o r t COMMITTEE OF EXPERTS ON THE EVALUATION OF ANTI-MONEY LAUNDERING MEASURES AND THE FINANCING OF TERRORISM (MONEYVAL) MONEYVAL(2018)15_SR Anti-money laundering and counter-terrorist
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 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 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 informationWAIVER AND MODIFICATION NOTICE
WAIVER AND MODIFICATION NOTICE To Address DFSA Firm Reference No. Notice No. Smart Crowd Limited The FinTech HIVE at DIFC, Level 4, Gate Precinct 5, DIFC, Dubai, UAE F004285 W582/2018 THE DFSA HEREBY GIVES
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 informationANTI-MONEY LAUNDERING POLICIES, CONTROLS AND PROCEDURES
ANTI-MONEY LAUNDERING POLICIES, STATEMENT It is the policy of this firm that all members of staff at all levels shall actively participate in preventing the services of the firm from being exploited by
More informationAML/CFT IMPLEMENTATION IN THE ESAAMLG REGION
AML/CFT IMPLEMENTATION IN THE ESAAMLG REGION P R E S E N T A T I O N A T A C G C C R O U N D T A B L E O N I M P R O V I N G T H E R E G U L A T I O N O F S O M A L I R E M I T T A N C E S H I L T O N
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 informationAnti-Money Laundering Update Domestic and European developments
Anti-Money Laundering Update Domestic and European developments Why Firms Need to Get this Right The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, as amended by the Criminal Justice
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 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 information9. SCREENING, AWARENESS AND TRAINING OF EMPLOYEES
AML/CFT Handbook for the Accountancy Sector 9. SCREENING, AWARENESS AND TRAINING OF EMPLOYEES 9.1 OF THE SECTION 1. One of the most important controls over the prevention and detection of money laundering
More informationAnti Money Laundering and Sanctions Rules and Guidance (AML)
Anti Money Laundering and Sanctions Rules and Guidance (AML) TABLE OF CONTENTS The contents of the AML Rulebook are divided into the following Chapters and sections: 1. INTRODUCTION... 1 1.1 Jurisdiction...
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 informationKeeping ahead of financial crime
Keeping ahead of financial crime 7 September 2016 www.moorestephens.co.uk PRECISE. PROVEN. PERFORMANCE. Agenda Introduction Tim West, Partner Market Abuse Regulation Giovanni Giro, Senior Manager The Fourth
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 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 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 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 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 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 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 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 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 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 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 informationFinancial Crime Supervision of the Fund Sector
Financial Crime Supervision of the Fund Sector Financial Crime Division Nick Herquin Paul Robinson Key Topics What is the FATF and Moneyval? How have international standards and mutual evaluations influenced
More informationNew AML Regime for the DIFC
Briefing note October 2012 New AML Regime for the DIFC The Dubai Financial Services Authority ("DFSA") has released Consultation Paper No. 86 regarding proposed changes to the DFSA's Anti-Money Laundering
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 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 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 informationTHEMATIC SUPERVISION EMERGING TRENDS CONG/DFSA OUTREACH 30 May 2016
THEMATIC SUPERVISION EMERGING TRENDS CONG/DFSA OUTREACH 30 May 2016 The goal of the Dubai Financial Services Authority (DFSA) in making this presentation is to provide you with easy to understand information
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 informationCONSULTATION PAPER P June Proposed Amendments To The Monetary Authority Of Singapore Act And Trust Companies Act
CONSULTATION PAPER P007-2014 June 2014 Proposed Amendments To The Monetary Authority Of Singapore Act And Trust Companies Act PREFACE To strengthen the regulatory framework for combating money laundering
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 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 informationCEBS / CEIOPS-3L / CESR/08-773
CEBS 2008 156/ CEIOPS-3L3-12-08/ CESR/08-773 16 October 2008 Common understanding of the obligations imposed by European Regulation 1781/2006 on the information on the payer accompanying funds transfers
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 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 informationJC /05/2017. Final Report
JC 2017 08 30/05/2017 Final Report On Joint draft regulatory technical standards on the criteria for determining the circumstances in which the appointment of a central contact point pursuant to Article
More informationCAYMAN ISLANDS. Supplement No. 2 published with Extraordinary Gazette No. 22 of 16th March, THE PROCEEDS OF CRIME LAW.
CAYMAN ISLANDS Supplement No. 2 published with Extraordinary Gazette No. 22 of 16th March, 2018. THE PROCEEDS OF CRIME LAW (2017 Revision) ANTI-MONEY LAUNDERING REGULATIONS (2018 Revision) Revised under
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 informationHigh-risk and non-cooperative jurisdictions
High-risk and non-cooperative jurisdictions FATF PUBLIC STATEMENT - 22 February 2013 Paris, 22 February 2013 - The Financial Action Task Force (FATF) is the global standard setting body for anti-money
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 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 informationMutual Evaluation Report 4 th Follow-Up Report for Saudi Arabia
Middle East and North Africa Financial Action Task Force Mutual Evaluation Report 4 th Follow-Up Report for Saudi Arabia Anti-Money Laundering and Combating the Financing of Terrorism 17 June 2014 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 February 2012 INTERNATIONAL STANDARDS ON COMBATING MONEY LAUNDERING AND THE
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 informationG20 High-Level Principles on Beneficial Owner Transparency (SPAIN)
G20 High-Level Principles on Beneficial Owner Transparency (SPAIN) The Spanish legislation is in line and complies with the revised FATF Standards. In this context, Spain recognizes the particular importance
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 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 informationAnti-money laundering thoughts from an AML/CFT supervisor
Anti-money laundering thoughts from an AML/CFT supervisor A speech delivered to the ACAMS 1 and FIU 2 Anti-Money Laundering and Countering Financing of Terrorism Seminar 2013 in Wellington On 20 June 2013
More informationAMENDMENTS TO THE MONEY LAUNDERING (JERSEY) ORDER 2008
POSITION PAPER NO. 1 2008 AMENDMENTS TO THE MONEY LAUNDERING (JERSEY) ORDER 2008 Money Laundering (Amendment No. 2) (Jersey) Order 200- ISSUED OCTOBER 2008 POSITION PAPER If you require any assistance
More informationSTATEMENT OF ANTI-MONEY LAUNDERING (AML) AND COMBATING THE FINANCING OF TERRORISM (CFT) POLICIES AND PRINCIPLES
STATEMENT OF ANTI-MONEY LAUNDERING (AML) AND COMBATING THE FINANCING OF TERRORISM (CFT) POLICIES AND PRINCIPLES Scope AstroBank Limited (the Bank ) has established and implemented appropriate policies
More informationDFSA Annual Supervision Outreach Breakout Group #1 Conduct of Business Risks. 25 June 2018
DFSA Annual Supervision Outreach Breakout Group #1 Conduct of Business Risks 25 June 2018 Breakout Group 1 - Agenda Opening Comments - Lawrence Paramasivam General Issues & Trends - Hend Al Budoor & Maryam
More informationQFC ANTI MONEY LAUNDERING REGULATIONS
QFC ANTI MONEY LAUNDERING REGULATIONS VER1-Sep05 QATAR FINANCIAL CENTRE REGULATION NO. 3 of 2005 QFC ANTI MONEY LAUNDERING REGULATIONS The Minister of Economy and Commerce hereby enacts the following regulations
More informationApplying for Authorisation. Notes for Applicants APPLICATION FORMS AND NOTICES (AFN) AUT - NOTES
For DFSA use only Applying for Authorisation Notes for Applicants These notes provide information that may assist you in completing the Core Information form, the various Fund forms, the Representative
More informationBermuda Anti- Money Laundering / Anti-Terrorist Financing
Bermuda Anti- Money Laundering / Anti-Terrorist Financing Frequently Asked Questions (FAQs) August 31, 2017 kpmg.bm Introduction On May 2, 2017, KPMG hosted a Question & Answer Panel Session on Anti-Money
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 informationANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM HANDBOOK JANUARY 2018
ANTI-MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM HANDBOOK JANUARY 2018 Whilst this publication has been prepared by the Financial Services Authority, it is not a legal document and should
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 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 informationJOINT RESOLUTION OF THE GOVERNOR OF BANK OF MONGOLIA AND CHAIR OF THE FINANCIAL REGULATORY COMMISSION
JOINT RESOLUTION OF THE GOVERNOR OF BANK OF MONGOLIA AND CHAIR OF THE FINANCIAL REGULATORY COMMISSION Date: June 30, 2016 Ulaanbaatar No A-162/195 In terms of article 19.2.3 of The Law on 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 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 informationImproving Global AML/CFT Compliance: on-going process 24 June 2016
Improving Global AML/CFT Compliance: on-going process 24 June 2016 Busan, Korea, 24 June 2016 - As part of its on-going review of compliance with the AML/CFT standards, the FATF identifies the following
More informationFAIS Newsletter. Inside this issue: From the FIC Desk: The journey to FICA compliance. Introduction
FAIS Newsletter Financial Services Board 04/12/2017 Volume 25 From the FIC Desk: The journey to FICA compliance Introduction The theme of this Newsletter is compliance with the Financial Intelligence Centre
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 informationTRUST COMPANY BUSINESS
TRUST COMPANY BUSINESS ON-SITE EXAMINATION PROGRAMME 2011 SUMMARY FINDINGS DOCUMENT OVERVIEW 1 Introduction... 2 2 Scope... 2 3 Process... 3 4 Overview... 3 5 Findings Arising From Examinations... 5 Corporate
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 informationANTI-MONEY LAUNDERING STATEMENT
ANTI-MONEY LAUNDERING STATEMENT In 1996, Cyprus enacted the Prevention and Suppression of Money Laundering Activities Law (hereinafter to be referred to as the Law ) which contains both suppressive and
More information1. ANZ supports the proposals to extend the AML/CFT Act to include those additional business sectors set out in Part 3 of the consultation paper.
22 September 2016 Ministry of Justice National Office Justice Centre 19 Aitken Street Wellington By email: aml@justice.govt.nz To whom it may concern ANZ submission on the consultation paper: Improving
More informationAct 3 Anti-Money Laundering (Amendment) Act 2017
ACTS SUPPLEMENT No. 3 ACTS SUPPLEMENT 26th May, 2017. to The Uganda Gazette No. 30, Volume CX, dated 26th May, 2017. Printed by UPPC, Entebbe, by Order of the Government. Act 3 Anti-Money Laundering (Amendment)
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 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 informationFinancial Crime Risk Return
Financial Crime Risk Return A Guide for Firms Contents Using this Guide... 1 Introduction... 2 Purpose... 2 Notes for Completion... 3 The FCR Return Start Page... 4 The FCR Return Reporting Suspicion...
More informationGuidance for the AML/CFT Statistical return Year ended 31 December 2016
for the AML/CFT Statistical return Year ended 31 December 2016 Introduction to CASCADE Over the course of the last 18 months the Authority has been working towards defining and developing a single supervisory
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 informationBY GRACE OF THE GOD ALMIGHTY THE GOVERNOR OF BANK INDONESIA,
BANK INDONESIA REGULATION NUMBER 19/ 10 /PBI/2017 CONCERNING IMPLEMENTATION OF ANTI-MONEY LAUNDERING AND PREVENTION OF TERRORISM FINANCING FOR NON-BANK PAYMENT SYSTEM SERVICE PROVIDER AND NON-BANK MONEY
More informationFSC's Response to IMF Report's Recommendations
FSC's to IMF Report's Recommendations IMF Recommendation AML/CFT R.05 & 8 Customer due diligence, including enhanced or reduced measures Review existing correspondent banking arrangements to ensure that
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 informationCESR/ CEBS/2008/39 CEIOPS-3L March 2008
CESR/08-247 CEBS/2008/39 CEIOPS-3L3-06-08 26 March 2008 Consultation on common understanding of the obligations imposed by European Regulation 1781/2006 on the information on the payer accompanying funds
More informationThe Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ) Completion Guidance 22 February 2018
The Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ) Completion Guidance 22 February 2018 1 Overview In response to both an increase in regulatory expectations as well as a call for
More informationCentral Bank of The Bahamas PUBLIC CONSULTATION
Central Bank of The Bahamas PUBLIC CONSULTATION Proposed Revisions to the Guidelines on the Prevention of Money Laundering & Countering the Financing of Terrorism I. INTRODUCTION 1. The Central Bank of
More informationForm ASP1 Ancillary Service Provider Application for registration
(For DFSA use only) Form ASP1 Ancillary Service Provider Application for registration Name of applicant Firms are requested to contact the authorisation department of the DFSA (+9714 362 1500) before considering
More informationThe DFSA Rulebook. Authorised Market Institutions (AMI) AMI/VER16/06-14
The DFSA Rulebook Authorised Market Institutions (AMI) PART 1: INTRODUCTION... 1 1. APPLICATION, INTERPRETATION AND OVERVIEW... 1 1.1 Application... 1 PART 2: APPLICATION AND AUTHORISATION... 3 2. APPLICATION
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 information