White Paper: The Development of the AML Regulatory Environment and the Future of Money Laundering Risk Management
|
|
- Susanna Smith
- 5 years ago
- Views:
Transcription
1 0 White Paper: The Development of the AML Regulatory Environment and the Future of Money Laundering Risk Management
2 1 Overview Over the past several decades, money laundering has emerged as a significant concern for financial institutions, law enforcement agencies and national governments. Most of the world s national governments have now implemented, and continue to refine, their antimoney laundering (AML) regulatory environments and law enforcement capabilities. Early rules-based regulatory efforts, such as the U.S. s Bank Secrecy Act (BSA), have been found to be effective only within the limited scope of controlling specific types of financial activity, such as large cash deposits. Most stakeholders in the successful prevention of money laundering activity now agree that allowing financial institutions and their regulators to adopt a risk-based approach to money laundering risk management is prudent, because it accounts for the wide range of permutations of customers, business activities and financial activities confronting different financial institutions. In this context, effective money laundering risk management requires a deep and thorough understanding of the financial services landscape and its money laundering vulnerabilities. Training that explores the financial services landscape and its associated risks is one necessary element of an effective money laundering risk management framework. Immersive scenario-based training which explores the money laundering risk analysis process using simulated financial services business contexts is also critical in developing an effective risk management framework. This white paper shows how the current AML regulatory environment developed, why it developed the way it did, and why training that offers both thorough coverage of the financial services business context and robust business simulations that explore the money laundering risk analysis process is a vital element of money laundering risk management efforts now, and will remain so over the decades to come. ProCert Training LLC, an IACET-accredited provider of continuing education units (CEUs), offers a wide range of online money laundering risk management courses designed to help individuals and institutions meet these training needs. This white paper therefore concludes with links to a diverse range of ProCert Training LLC money laundering risk management courses.
3 2 Introduction Money laundering is the movement of money designed to make the proceeds of criminal activity appear to have been earned through legitimate means. Money laundering regulations are quite a new innovation, but they have had a profound impact on the way the financial services industry and other industries conduct their business. In order to manage money laundering risks effectively, you need to understand them. In your quest to develop robust money laundering risk management skills, however, you can also benefit from knowing how money laundering regulations work, how they developed, and where the regulatory environment is likely headed. This white paper is therefore primarily designed to help you understand: Why money laundering regulations exist How they developed What they will likely look like in the future Deep History As a matter of statute and regulation, money laundering is a relatively new concept, dating back only as far as the early 1970s. Communities, governments and the banking industry have, however, been managing the risks associated with handling the proceeds of criminal activity for millennia. In the pre-modern era, an individual arriving in a new community with a significant amount of money would be asked many of the same questions that apply to a modern banking business: How did you come by this money? Are you a thief? A pirate? An influential merchant? A successful rabbit farmer? Before we admit you to our community, you must prove that you came by this wealth through lawful means.
4 3 Context While disguising the origins of money is quite an old game, the rules of the game have changed dramatically over the past forty years. This white paper will show you how and why money laundering regulations have developed, the imperatives that led to their development, and how these historical trends have resulted in the current shape of the global financial services regulatory landscape. This historical context will further your understanding of how and why the financial services industry analyses and manages money launderingrelated risks, and where the money laundering regulatory environment appears to be headed. Converging Forces In order to understand the current state of money laundering regulations, it is necessary to consider the relationship between a number of related topics: the development of civil society and the rule of law the concept of the nation the nature of democracy the multilateral trade system the expanding universe of criminal statutes the rapid development of the financial services industry Presenting these relationships adequately could easily occupy an entire library, so what follows is necessarily a simplistic sketch.
5 4 Crime Societies decide what is criminal that is, activity subject to punishment due its harmful effects. Activities now considered criminal in many countries were not considered criminal in the past (such as narcotics use), while activities widely criminalized in the past (such as adultery) are generally not currently considered criminal offenses. What is considered criminal is therefore a reflection of current standards of social behavior, which is manifested through government policy, legislation and regulations. International Trade The development of the world s current free-market economy required the formation of multiple democratic societies founded on the rule of law. Democratic governments and their legislative and legal institutions serve as guarantors of contracts, which form the basis for trade relationships and commercial activity, and of currency, through which payment for goods and services is made. The development required of countries as they enter the arena of global commerce is therefore away from the arbitrary exercise of power by a few individuals and toward the exercise of power through government institutions with relative consistency over time. Corruption and bribery, especially at the national level, have therefore increasingly become criminal offenses as countries seek to expand their global trading presence: uncertainty impedes trade.
6 5 Modern Crime The development of modern society has been marked by an expanding universe of available goods and services (through trade and innovation), accompanied by an increasingly complex financial services sector and an increase in the range of criminal offenses. While the primary criminal offenses of earlier days related to crimes against property rights (theft, fraud etc.), the modern criminal landscape now often includes crimes related to activities that cause damage to individual wellbeing (such as narcotics use, prostitution, counterfeit goods) and crimes against public wellbeing (such as corruption). Example: Prohibition Unless criminalization produces a rapid reduction in criminal behavior, increasing the range of activities that are considered criminal necessarily produces an increase in the amount of money generated through illegal means. Taking the U.S. s experiment in prohibiting the consumption of alcohol (the Prohibition era) as an example, criminalizing alcohol consumption did not significantly alter social behavior, but did make selling alcohol a more profitable business, and a business in which the profits were concentrated into a much smaller number of coffers. Instead of thousands of bars and liquor stores making modest profits that were subject to taxation and government control, the smaller number of people controlling the illegal trade in alcohol (bootleggers, moonshiners and speakeasy operators) quickly became wealthy.
7 6 Regulatory Imperatives The recent development of money laundering regulations was largely the result of a confluence of events: The criminalization of activities (such as narcotics use and prostitution) that had previously been legal The increasing availability of illegal goods (such as narcotics and prostitutes) due to expanding trade opportunities Increasing opportunities to commit existing criminal offenses (such as theft and fraud) due to the expansion of the global financial system An increased emphasis on the importance of protecting the welfare of all citizens from government officials acting in their own interest (such as is the case with corruption and bribery) A country s development and enforcement of money laundering regulations is, above all, a policy consideration related to its desire to benefit from international commerce. Toward the Bank Secrecy Act The U.S. took an early lead in the development of regulations designed to criminalize the movement of money associated with criminal activities. During the Prohibition era, U.S. prosecutors relied on criminal statutes against tax evasion to prosecute bootleggers and other criminals. During the post- World War II era, the U.S. experienced a massive increase in illegal narcotic use, primarily heroin and cocaine, and sought a way to distinguish consumption from distribution in terms of prosecution.
8 7 As with the earlier use of tax evasion penalties, there was also an interest in using asset forfeiture as a means of forcing criminals to disgorge the profits from their crimes. The Bank Secrecy Act The U.S. passed the Bank Secrecy Act (the BSA ) in This law was an early and influential effort to align bank behavior with prosecutorial interests. The BSA placed an obligation on banks to report certain types of behavior (large cash deposits, purchases of monetary instruments with cash, and suspicious customer activity) to the U.S. government. The BSA has since been amended numerous times (such as through the USA PATRIOT Act), especially in terms of expanding the scope of reporting obligations beyond depository institutions. Other national governments have gradually followed suit, creating their own reporting requirements, often because of the downstream impact on countries that do not adopt reporting requirements: Activity (such as sizeable cash deposits) that formerly occurred in Country A will now occur in Country B if Country A has reporting requirements and Country B does not. Forty Recommendations In 1989, the G7 members of the OECD initiated the creation of the Financial Action Task Force (FATF), which is charged with aligning national money laundering statutes and regulations with a set of FATF-developed industry best practices known as the Forty Recommendations. The FATF continues to review national money laundering regulatory frameworks periodically to determine the extent of their alignment with these original recommendations, as well as with subsequent recommendations, and issues public reports of their findings.
9 8 National money laundering regulatory frameworks are therefore assessed on a regular basis against the FATF s international standards. International Pressure Significant deviation from FATF expectations can cause severe problems for a country s financial services industry due to international political pressure, as well as reluctance on the part of financial institutions from other countries to deal with financial institutions or transactions involving a country that the FATF has found to be deficient in its money laundering control framework. This reluctance becomes particularly acute when the FATF places a country on its Noncooperative Countries and Territories (NCCT) list. Since its first issuance in 2000, fear of being placed on the NCCT list has become one of the primary means of influencing the development of strong national regulatory frameworks. While there now exist very few countries that lack a strong money laundering regulatory regime in terms of statute, the effectiveness of enforcement of these statutes varies widely between countries. The Risk-based Approach The most significant development in money laundering risk control efforts during the past forty years has been an increased recognition that a rules-based regulatory framework (such as the original BSA) cannot effectively identify or prevent money laundering activity across much of the enormous range of financial services business types, financial services activities, business activities and jurisdictions now active on the world stage. The FATF and national regulators are therefore often increasingly open to pursuing a risk-based approach, which seeks to align a financial institution s money laundering risk management framework with its specific risks, which are formed through a unique
10 9 combination of customers, business activities and scope of operations. The Wolfsberg Group s statement on the risk-based approach, issued in 2006, continues to form one of the most influential documents in this ongoing debate. The Future of Money Laundering Regulations The international trend toward managing money laundering risks through a risk-based approach continues to gain both importance and validity. While there will likely always remain some rules-based reporting requirements (for example, related to specific transaction types such as cash deposits), international standards, national regulatory frameworks and financial institution operations are increasingly founded on one of the core principles of the risk-based approach, which is that money laundering risks need to be understood thoroughly before they can be managed effectively. The emphasis is increasingly on risk analysis and risk assessment, which seek to align a financial institution s risk management framework with its specific money laundering risks, rather than simply on compliance with reporting requirements designed to capture only a fraction of the world s business and financial activity. The amlrisktraining.com / ProCert Training LLC Course Suite Our course suite has been specifically designed to help financial services industry participants, regulators and law enforcement officials analyze money laundering risks in order to manage them effectively. Other courses may offer guidance on fulfilling the mandates of earlier reporting regimes, but our course suite offers comprehensive, scenario-based training in how to analyze money laundering risks in order to manage them effectively. This money laundering risk management training has been created to develop effective money laundering risk management capabilities suitable for the next forty years and beyond. Please feel free to explore the full range of our course offerings at to learn how we can help you and your organization develop and operate an effective money laundering risk management framework.
11 10 Course Overviews We offer over a dozen different online classes, so there is likely an offering that would meet your needs based on your relationship to the financial services industry and your level of experience. Financial services professionals who need to understand the basic framework for identifying and managing money laundering risk will benefit from our 2-hour AML Core Competence course, while more experienced professionals will benefit from courses that target the money laundering risks associated with the major financial services business areas (private banking, retail financial services, commercial banking and investment management). Regardless of your experience level, you will enjoy our Advanced Tactical Training, a scenario-based course which embeds you within four different business situations where you need to exercise effective risk management skills. Law enforcement officials will benefit from this same set of courses, since these courses offer thorough training in the risk analysis skills needed to identify unusual and potentially suspicious activity in a specific financial services business context. AML Officers and regulators will benefit from any of the courses described above, but will receive the additional training they need to analyze and manage money laundering risks from a strategic (high-level) and programmatic level by taking our 20-hour AML Officer Master Class. This course incorporates many of the elements contained in our other courses, but adds thorough training in the use of the types of risk analysis frameworks required for successful operation of a financial institution s AML program. Pricing and enrollment options for all of our courses are available by consulting our course catalog. Institutional customers should contact us direct for inquiries related to wholesale pricing, course customization possibilities and course distribution options. We looking forward to meeting your training needs soon!
IRS Criminal Investigation
IRS Criminal Investigation Overview IRS Criminal Investigation IRS Strategic Plan FY2013 Year in Review Emphasis Areas IRS Criminal Investigation 3,647 employees worldwide 2,554 Special Agents IRS Criminal
More informationAnti-Money Laundering Update: Regulations, Enforcement Actions and Red Flags
Fiduciary and Investment Risk Management Association 28 th National Risk Management Training Conference Anti-Money Laundering Update: Regulations, Enforcement Actions and Red Flags April 30, 2014 Michael
More informationTrans-Fast Remittance LLC. AML Compliance Training for Agents
Trans-Fast Remittance LLC AML Compliance Training for Agents 2016 Trans-Fast expects all of its agents to adhere to the following: terms of agent agreement; establish AML Program as per Section 352 of
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 informationAGENT ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM FOR MONEY ORDER SALES
AGENT ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM FOR MONEY ORDER SALES Revision as of January 17, 2018 Explanation/Training Video Link: www.northamericanmoneyorder.com/aml This Program should be reviewed
More informationa. Domestic money laundering statutes and laws i. Bank Secrecy Act of 1970
HIGH- STAKES TAX DEFENSE & COMPLEX CRIMINAL DEFENSE 1012 Broad Street, 2nd Fl Bloomfield, NJ 07003 Tel (973) 783-7000 Fax (973) 338-3955 www.deblislaw.com Anti- Money Laundering Tools a. Domestic money
More informationRegional Risk Spotlight: An Interview with Michael Kim of Kobre & Kim on South Korea s Anti-Money Laundering Laws
Regional Risk Spotlight: An Interview with Michael Kim of Kobre & Kim on South Korea s Anti-Money Laundering Laws By Megan Zwiebel While anti-corruption compliance is a focus for many companies, anti-money
More informationBox 1.1 Anti money laundering and combating terrorism financing
1 Chasing Dirty Money Money laundering is the conversion of criminal incomes into assets that cannot be traced back to the underlying crime. Over the past three decades, the number and scope of laws and
More informationCouncil of Europe COMMITTEE OF MINISTERS
Word FranГais Explanatory Memorandum Council of Europe COMMITTEE OF MINISTERS Recommendation Rec(2001)11 of the Committee of Ministers to member states concerning guiding principles on the fight against
More information- Due diligence process is a continuous process customer service representatives (C/S Rep.) need to be aware of:
ANTI MONEY LAUNDERING The Fundamental Principles of The Policy Overview The internal policy of The UNBE is to prevent and combat money laundering. This includes financial monitoring, which is in conformity
More informationAnti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide
Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide Insert Business Name Here Date of Adoption of this Anti-Money Laundering Program ANTI-MONEY LAUNDERING AND TERRORIST
More information10 ESSENTIAL TERMS FOR BITCOIN REGULATION
In March 2013, the U.S. Financial Crimes Enforcement Network (FinCEN) classified Bitcoin and Virtual Currency exchanges as Money Services Businesses (MSB s) in the U.S., which are financial businesses
More informationACFE and ACAMS South Florida Chapter 2015 AML/Fraud Conference
ACFE and ACAMS South Florida Chapter 2015 AML/Fraud Conference Marc Benson Director, Global Investigations & Compliance Navigant Consulting Inc. Salvatore LaScala Managing Director, Global Investigations
More informationMODERNIZING ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING LAWS AND REGULATIONS. White Paper July
MODERNIZING ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING LAWS AND REGULATIONS White Paper July 2018 www.icba.org TABLE OF CONTENTS Introduction...3 Modernization will produce more useful information
More informationAnti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide
Anti-Money Laundering and Terrorist Financing Prevention Compliance Program Creation Guide Compliance Program Creation Guide January 2015 1 Compliance Program Creation Guide January 2015 2 Insert Business
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 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 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 informationAnti-Money Laundering Measures in the British Virgin Islands
Anti-Money Laundering Measures in the British Virgin Islands Preface This publication has been prepared for the assistance of those who are considering the law of the British Virgin Islands ( BVI ) as
More informationNew Coordinates. Boards of Directors Face Growing AML Accountability By Saverio Mirarchi
From New Coordinates Boards of Directors Face Growing AML Accountability By Saverio Mirarchi Bank Boards of Directors are coming under mounting pressure to ensure effective Anti-Money Laundering (AML)
More informationHOW TO LOCATE ASSETS DURING A FINANCIAL CRIMES/NARCOTICS INVESTIGATION
HOW TO LOCATE ASSETS DURING A FINANCIAL CRIMES/NARCOTICS INVESTIGATION This one-day course will benefit any detective and/or prosecutor assigned to white collar crime/narcotics investigations. Preliminary
More information(AGA) DA: 6, 2019 RE:
TO: Members of the 116 th Congress FR: American Gaming Association (AGA) DA: February 6, 2019 RE: Casino Gaming Industry Priorities in 2019 and Beyond AGA and Casino Gaming Overview Based in Washington,
More informationINVESTIGATING AND PROSECUTING MONEY LAUNDERING
INVESTIGATING AND PROSECUTING MONEY LAUNDERING This one-day course will discuss the criminal elements and case law for N.J.S.A criminal statue 2C:21-25, Financial Facilitation of Criminal Activity, also
More informationAnti-Money Laundering and U.S. Compliance
U.S. Regulatory/Compliance Orientation for International Bankers Anti-Money Laundering and U.S. Compliance Conference of State Bank Supervisors & Institute of International Bankers New York City, New York
More informationHOW TO LOCATE ASSETS DURING A FINANCIAL CRIMES/NARCOTICS INVESTIGATION
HOW TO LOCATE ASSETS DURING A FINANCIAL CRIMES/NARCOTICS INVESTIGATION This one-day course will benefit any detective and/or prosecutor assigned to white collar crime/narcotics investigations. Preliminary
More informationLiberty Bankers Life Insurance Company
Liberty Bankers Life Insurance Company Anti-Money Laundering (AML) Policy Introduction In compliance with the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and
More informationIntroduction. Background on Money Laundering. Background on Terrorist financing. Bank Secrecy Act (Regulations)
XM - US Compliance Introduction Background on Money Laundering Background on Terrorist financing Bank Secrecy Act (Regulations) How MSB (Money Service Business) can help to prevent Money Laundering & Terrorist
More informationAnti-Money Laundering. How to set up a strong Compliance Program
Anti-Money Laundering How to set up a strong Compliance Program Importance of AML Protection Financial institutions face a growing number of threats from criminals that seek to misuse the U.S. financial
More informationHSI SAC Newark NJ Kelly Polson & Terri Quintana Cornerstone Outreach Program
Homeland Security HALF PHOTO SLIDE PAGE TITLE FOR QUOTES AND SUCH HSI SAC Newark NJ Kelly Polson & Terri Quintana Cornerstone Outreach Program Homeland Security Legacy HSI investigates customs, trade and
More informationAccelerated International Momentum to Return Stolen Assets
Series Accelerated International Momentum to Return Stolen Assets United Nations Office on Drugs and Crime (UNODC) UNODC World Bank Stolen Asset Recovery Initiative (StAR) July 2016 More Information http://www.un.org/esa/ffd/ffd-follow-up/inter-agency-task-force.html
More information$OOÃULJKWVÃUHVHUYHGÃ$SSOLFDWLRQVÃIRUÃSHUPLVVLRQÃWRÃUHSURGXFHÃDOOÃRUÃSDUWÃRIÃWKLVÃSXEOLFDWLRQ
)LQDQFLDO$FWLRQ7DVN)RUFH RQ0RQH\/DXQGHULQJ *URXSHG$FWLRQ)LQDQFLqUH VXUOH%ODQFKLPHQWGH&DSLWDX[ 5HSRUWRQ1RQ&RRSHUDWLYH&RXQWULHV DQG7HUULWRULHV Ã)HEUXDU\Ã $OOÃULJKWVÃUHVHUYHGÃ$SSOLFDWLRQVÃIRUÃSHUPLVVLRQÃWRÃUHSURGXFHÃDOOÃRUÃSDUWÃRIÃWKLVÃSXEOLFDWLRQ
More informationAML POLICY OTM CAPITAL (OTM VENTURES INC) ANTI-MONEY LAUNDERING ("AML") POLICY STATEMENT AND PRINCIPLES SCOPE OF POLICY
AML POLICY OTM CAPITAL (OTM VENTURES INC) ANTI-MONEY LAUNDERING ("AML") POLICY STATEMENT AND PRINCIPLES SCOPE OF POLICY This policy applies to all OTM CAPITAL officers, employees, appointed producers and
More informationBSA Modernization Can Strengthen Law Enforcement and Ease Compliance
November 29, 2018 BSA Modernization Can Strengthen Law Enforcement and Ease Compliance On behalf of the more 52,000 community bank locations across the nation represented by ICBA, we thank Chairman Crapo,
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 informationANTI-MONEY LAUNDERING COMPLIANCE GUIDE
ANTI-MONEY LAUNDERING COMPLIANCE GUIDE Revision as of January 17, 2018 This revision supersedes and replaces all other Anti-Money Laundering Compliance Guides issued by North American Money Order Company,
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 informationA monthly publication from South Indian Bank. To kindle interest in economic affairs... To empower the student community...
To kindle interest in economic affairs... To empower the student community... Y en s Op cces A A monthly publication from South Indian Bank www.sib.co.in ho2099@sib.co.in South Indian Bank has launched
More informationOpinion paper MEGATREND FINANCIAL CENTRE
www.pwc.ch/financial-services Opinion paper MEGATREND FINANCIAL CENTRE Tax transparency is going digital and is on the increase Three theories on the consequences of digital transformation for financial
More informationFuture Law: Anti-Money laundering and the legal profession. Presented by: Jonathan Smithers. CEO, Law Council of Australia
Future Law: Anti-Money laundering and the legal profession Presented by: Jonathan Smithers CEO, Law Council of Australia Thursday 26 October 9am 10am Conference of Regulatory Officers Adelaide, 26 27 October
More informationANTI-MONEY LAUNDERING
ANTI-MONEY LAUNDERING 1. INTRODUCTION 2 2. WHY IS COMBATING MONEY LAUNDERING SO IMPORTANT FOR COMPANIES AND INVESTORS? 5 3. ADVICE FOR FUND MANAGERS 6 4. FURTHER RESOURCES 13 1. INTRODUCTION CDC defines
More informationOPENING REMARKS. Caribbean Financial Action Task Force AML/CFT Compliance Conference
OPENING REMARKS at the Caribbean Financial Action Task Force AML/CFT Compliance Conference by Ewart S. Williams Governor, Central Bank of Trinidad and Tobago December 04, 2007 I would like to commend the
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 informationBank Secrecy Act (BSA) BSA-AML-OFAC-CIP Overview
Bank Secrecy Act (BSA) BSA-AML-OFAC-CIP Overview What is the BSA? The Bank Secrecy Act (BSA) requires all financial institutions, casinos, and certain other businesses to: Monitor customer behavior File
More informationCOMMISSIONER ALGIRDAS ŠEMETA TAXATION, CUSTOMS, STATISTICS, AUDIT AND ANTI- FRAUD
COMMISSIONER ALGIRDAS ŠEMETA TAXATION, CUSTOMS, STATISTICS, AUDIT AND ANTI- FRAUD SPEECH AT THE EUROPEAN SERIOUS & ORGANISED CRIME CONFERENCE 2013 WINNING THE FIGHT 28 th February 2013 KEYNOTE SPEECH Ladies
More informationSESSION 3. RED FLAGS & Counter Terrorist Financing
SESSION 3 RED FLAGS & Counter Terrorist Financing 1 Exercise 6: Presentation of Buyer/ Applicant Documents Seller/ Beneficiary Document Presenting Bank Nominated or Not If nominated, presentation tolls
More informationBank Secrecy Act- USA Patriot Act Compliance
Bank Secrecy Act- USA Patriot Act Compliance Federal Laws Regulating Money Service Businesses Bank Secrecy Act (1970) Establishes recording of high dollar transactions & the reporting of suspicious activity
More informationProtecting Native American casinos from money-laundering risks
Protecting Native American casinos from money-laundering risks For the vast majority of patrons, Native American casinos are ideal destinations for entertainment and leisure. Casinos are cash-intensive
More informationBank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training
Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Employee & Agent Training OVERVIEW The Bank Secrecy Act, or BSA, was passed by congress in 1970. The BSA required banks to maintain records of certain
More informationAnti-Money Laundering Policy and Procedure
PA Housing Limited Anti-Money Laundering Policy and Procedure November 2017 Owning manager Simon Hatchman Department Finance Approved by Audit & Risk Committee 2 November 2017 Next review date October
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 informationUPDATE ON CANADA S 2008 ANTI-MONEY LAUNDERING REQUIREMENTS FOR CAs
UPDATE ON CANADA S 2008 ANTI-MONEY LAUNDERING REQUIREMENTS FOR CAs Chartered accountants and accounting firms are not on the front line in the war against money laundering and terrorist financing! But,
More informationFINANCIAL CRIMES LAW IN NEW JERSEY
FINANCIAL CRIMES LAW IN NEW JERSEY This one-day course will provide a detailed analysis of N.J.S.A Chapters 20 & 21 related to financial crimes investigations. Case studies will describe key elements for
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 informationINVESTIGATING AND PROSECUTING MONEY LAUNDERING
INVESTIGATING AND PROSECUTING MONEY LAUNDERING This one-day course will discuss the criminal elements and case law for N.J.S.A criminal statue 2C:21-25, Financial Facilitation of Criminal Activity, also
More informationAnti-Money Laundering
INFORMATIONAL Anti-Money Laundering NASD Provides Guidance To Member Firms Concerning Anti-Money Laundering Compliance Programs Required By Federal Law SUGGESTED ROUTING The Suggested Routing function
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 informationFINRA E-Learning Courses
FINRA E-Learning Courses The Definitive Source for Firm Element Training FINRA develops a wide range of e-learning courses for registered representatives, supervisors, operations staff, compliance personnel
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 informationMETHODS OF LOCATING AND SEIZING HIDDEN ASSETS
METHODS OF LOCATING AND SEIZING HIDDEN ASSETS This one-day course will benefit any detective and/or prosecutor assigned to white collar crime/narcotics investigations. Preliminary discussion will center
More informationCITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM
I. Introduction CITIZENS, INC. BANK SECRECY ACT/ ANTI-MONEY LAUNDERING POLICY AND PROGRAM The Bank Secrecy Act/Anti-Money Laundering Responsibilities of Insurance Companies U.S. insurance companies have
More informationBest practices in the tax administration for sustained revenue increase for social development
Best practices in the tax administration for sustained revenue increase for social development 1. Context The starting point of this discussion should be, necessarily, to remember that tax revenues are
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 informationDevelopments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals. May 2016
Developments in Anti-Money Laundering Regulation for Investment Advisers and Funding Portals May 2016 John L. Sullivan Washington, D.C. jlsullivan@wsgr.com Michael Chiswick-Patterson Washington, D.C. mchiswickpatterson@wsgr.com
More informationThe Bribery Act 2010:
The Bribery Act 2010: Overview Introduction The Bribery Act 2010 (the Act ) came into force on 1 July 2011. The main four offences under the Act are: 1. bribing another person (section 1); 2. being bribed
More informationPREVENTION OF MONEY LAUNDERING AND FINANCING OF TERROR, AND CUSTOMER IDENTIFICATION
Page 411-1 PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERROR, AND CUSTOMER IDENTIFICATION Introduction 1. (a) Effective knowledge of banking corporations customers, including an understanding of the
More informationGovernment Personnel Mutual Life Insurance Company. Anti-Money Laundering (AML) Program; Including Suspicious Activity Reports
Government Personnel Mutual Life Insurance Company Anti-Money Laundering (AML) Program; Including Suspicious Activity Reports Policies, Procedures, Internal Controls For Compliance With the Patriot Act
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! 1 The ABC s of AML: An Introduction
More informationThe Role of Accountants in the Fight against Money Laundering
The Role of Accountants in the Fight against Money Laundering Presentation by: Felicity Banks Head of Business Law Institute of Chartered Accountants in England & Wales Money Laundering and Terrorist Financing
More informationBRIBERY IN INTERNATIONAL BUSINESS TRANSACTIONS
BRIBERY IN INTERNATIONAL BUSINESS TRANSACTIONS GLOBAL Headquarters the gregor building 716 West Ave Austin, TX 78701-2727 USA TABLE OF CONTENTS I. INTRODUCTION 1BCourse Overview... 2 94BMajor International
More informationAnti-Money Laundering and U.S. Compliance
Institute of International Bankers & Conference of State Bank Supervisors U.S. Regulatory/Compliance Orientation 2010 PATTON BOGGS LLP Anti-Money Laundering and U.S. Compliance New York City, New York
More informationNew Federal Initiatives Project. FERA 2009 Brings U.S. Broad New Government Enforcement Powers
New Federal Initiatives Project FERA 2009 Brings U.S. Broad New Government Enforcement Powers By Michael J. Madigan, Lauren B. Muldoon and Jane Beall** September 14, 2009 The Federalist Society for Law
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 informationAnti-Money-laundering and Countering the Financing of Terrorism
Anti-Money-laundering and Countering the Financing of Terrorism A Partnership for National Unity Georgetown March 2014 1 A Partnership for National Unity 61 Hadfield Street, Werk-en-Rust Georgetown Co-operative
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 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 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 informationgamevy Anti- Money Laundering Detecting and Preventing Financial Crime Training for Gamevy
gamevy Anti- Money Laundering Detecting and Preventing Financial Crime Training for Gamevy Introduction This document is Gamevy s training on anti- money laundering regulations within the context of our
More information2017 Annual Seasonal Conference of the. International Section of the New York State Bar Association, Antigua, Guatemala
2017 Annual Seasonal Conference of the International Section of the New York State Bar Association, Antigua, Guatemala Panel 15 Compliance Trends and Developments in Insurance/Reinsurance: A Regional Overview
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK ASSESSMENT OF CIVIL MONEY PENALTY
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) ) ) Number 2017-02 Merchants Bank of California, N.A. ) Carson, California ) ASSESSMENT OF
More informationBSA/AML ENFORCEMENT. See 12 U.S.C (2000).
MONEY LAUNDERING AND CRIMINAL PROSECUTIONS OF BANKS: A FOCUS OF BANK ENFORCEMENT ACTIVITY IN RECENT YEARS By Thomas P. Vartanian and Dominic A. Labitzky * Bank Secrecy Act and Anti-Money Laundering (BSA/AML)
More informationTokenLot, LLC BSA Officer TokenLot, LLC Board of Directors
Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Program APPROVED BY TokenLot, LLC BSA Officer TokenLot, LLC Board of Directors TokenLot, LLC BSA/AML Program 2017 1 TABLE OF CONTENTS 1. Bank Secrecy
More informationBank Of America Corporation Aml Policy Manual
Bank Of America Corporation Aml Policy Manual American Gaming Association. Best Practices Bank Secrecy Act and associated anti-money laundering (AML) statutes and regulations. Risk- The goal of this document
More informationThe Financial Intelligence Service
Guernsey Authorities Official Guernsey Government Website: http://www3.gov.gg/ccm/navigation/government/ Financial Investigation Unit (FIU) Website: http://www.guernseyfiu.gov.gg/ The Financial Intelligence
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 informationANTI-MONEY LAUNDERING ( AML ) POLICY OF BullM Global Limited
ANTI-MONEY LAUNDERING ( AML ) POLICY OF BullM Global Limited POLICY STATEMENT AND PRINCIPLES BullM Global Limited ( BULLM ) has adopted an Anti-Money Laundering (AML) compliance policy ( Policy ) according
More informationAlcohol and Gaming Commission of Ontario Submissions to the Senate Committee on Legal and Constitutional Affairs October 18, 2012
Introduction: Alcohol and Gaming Commission of Ontario Submissions to the Senate Committee on Legal and Constitutional Affairs October 18, 2012 The Standing Senate Committee on Legal and Constitutional
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 informationBribery and Corruption
Bribery and Corruption Legal Elements of Bribery and Corruption 2018 Association of Certified Fraud Examiners, Inc. 2018 Association of Certified Fraud Examiners, Inc. 1 of 27 Introduction This section
More informationBGLC WELCOMES YOU TO THE Anti-Money Laundering Training Session now Proceeds of Crime Act (POCA) 2007:
BGLC WELCOMES YOU TO THE Anti-Money Laundering Training Session now Proceeds of Crime Act (POCA) 2007: What is Money Laundering? 1. The term Money Laundering refers to all procedures, methods and transactions
More informationQuestions to the Association of German Banks
Questions to the Association of German Banks 1. Do you consider these current anti-money laundering and anti-tax evasion rules for banks to be adequate? If not, do you have any suggestions to improve these
More informationFXPRIMUS ANTI-MONEY LAUNDERING ("AML") POLICY
FXPRIMUS ANTI-MONEY LAUNDERING ("AML") POLICY POLICY STATEMENT AND PRINCIPLES In compliance with The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA 2002), the Prevention of Corruption
More informationOECD draft Guidance to Counter Illicit Trade: enhancing transparency in Free Trade Zones
OECD draft Guidance to Counter Illicit Trade: enhancing transparency in Free Trade Zones Having Regard to Article 5 b) of the Convention on the Organisation for Economic Cooperation and Development of
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 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 informationIdentify your jurisdiction s money laundering and anti-money laundering (AML) laws and regulations. Describe the main elements of these laws.
Nigeria Babajide O Ogundipe and Chukwuma Ezediaro Sofunde, Osakwe, Ogundipe & Belgore Domestic legislation 1 Domestic law Identify your jurisdiction s money laundering and anti-money laundering (AML) laws
More informationPayroll Agents Sector Specific AML/CFT Guidance Notes December 2015
Payroll Agents Sector Specific AML/CFT Guidance Notes December 2015 Whilst this publication has been prepared by the Financial Services Authority, it is not a legal document and should not be relied upon
More informationConversations: Jeffrey Owens and Rick McDonell
Volume 75, Number 9 September 1, 2014 Conversations: Jeffrey Owens and Rick McDonell Reprinted from Tax Notes Int l, September 1, 2014, p. 763 Conversations: Jeffrey Owens and Rick McDonell Jeffrey Owens
More informationUNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK
UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF: ) ) ) ) Number 2017-04 Lone Star National Bank ) Pharr, Texas ) ASSESSMENT OF CIVIL MONEY PENALTY
More informationTajikistan Short Form Report - May 2017
Sanctions FAFT AML Deficient Higher Risk Areas Medium Risk Areas None No US Dept of State Money Laundering assessment Compliance with FATF 40 + 9 Recommendations Not on EU White list equivalent jurisdictions
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 information