Integrity in Mobile Financial Services
|
|
- Joseph Eustace Dawson
- 5 years ago
- Views:
Transcription
1 Integrity in Mobile Financial Services AFI, SBS Peru and WB Forum, Lima Peru, May Pierre Laurent Chatain Lead Financial Sector Specialist (Financial Systems) The World Bank Wameek Noor Consultant (Financial Systems) The World Bank Najah Dannaoui Consultant (Financial Systems) The World Bank
2 New Research 2 Anatomy of Current Mobile Money Business Models New Outcomes in terms of Risk Stocktaking of Regulatory Practices and Related Policy Guidance Currently Observed on these contentious topics KYC/CDD Agents Regulation Reporting Obligations Supervisory/Enforcement Responsibilities Other Contentious Issues UK, France, Russia, Kenya, Zambia, Malaysia, Philippines and Mexico
3 New Outcomes in terms of Risk 3 Our Risk Matrix is Still Valid (Anonymity, Elusiveness, Rapidity and Lack of Oversight) Mobile Money less risky than cash No new ML or TF risks found in Mobile Money (Cases of Consumer Fraud Observed) Can be used strategically to lower national ML/TF risks by facilitating the move away from higher risk cash transactions to lower risk mobile money transactions Smart Risk Mitigation Practices Utilized by M-Money Providers and Regulators
4 Risks Associated to M-FS 4 From Regulators IT security consumer protection AML/CFT From Industry Too much regulation kills the business From Policymaker Financial inclusion impeded
5 Mobile Money Less Risky Than Cash 5
6 6 No ML or TF risks found in Mobile Money but Cases of Consumer Fraud Observed Philippines Experience Case 1: Using Multiple SIM Cards but through one Phone Case 2: Many Transactions to One
7 Case 1 7 Amount transferred to a mobile phone through G-Cash Mr. A ordered an Iphone from Mr. B through Ebay Iphone was never received by Mr. A Mr. B Transferred the corresponding amount to a mobile phone Mr. E went to G-Cash business center Mr. E s mobile account Transferred the corresponding amount to a mobile phone Mr. D s mobile account Transferred the corresponding amount to a mobile phone Mr. C s mobile account Mr. E Mr E. cashed out victim s money using his mobile phone
8 Case 2 8 Mr. A & Mr. B Advertised fake overseas employment offers as caregivers and nurses Money collected through G-Cash remittances the promised deployment abroad never materialized VICTIMS Sent between $65 and $975 for training and processing fees
9 9 Innovative Risk Mitigation Practices Utilized by M-Money Providers Smaller payments (size of transactions and volume of payments) including capping. Smurfing is a risk but can lead to easier detection Limitations of cross-border operations and operations in foreign currencies Geographical restrictions Limitation to one account for one cellular phone. Irrespective of business model, sophisticated internal control/detection systems
10 Observed Control Measures 10 Type of Risk Possible ML/TF Risks Key Control Measures Anonymity Elusiveness Off-the-branch or non-face-to-face customer origination Unauthorized use of mobile phones for financial transactions Use of mobile phone at the layering stage of the ML process Use of multiple m-fs accounts Cross-border mobile-to-mobile remittances Innovative KYC and identity verification procedures MTN Banking SA Wizzit - SA Advanced identification mechanisms Bradesco Brazil Korea Limits on transactions Korea FSS Customer profiling Brazil Reporting Macau SAR China Monitoring Korea Malaysia In-field service risk assessment Hong Kong FIU Identification of sender Maxis Malaysia
11 Observed Control Measures (cont d) 11 Type of Risk Rapidity External Legal issue: Poor oversight Possible ML/TF Risks Lack of capacity to monitor/freeze real-time messaging and settlement Oversight loopholes for providers Lack of regulation, supervision of new providers M-FS Shell companies Key Control Measures Integrated system of internal controls Itau Brazil Philippines Managing risk of 3rd party service providers Wizzit South Africa Guidelines on m-fs and risk management Philippines, Korea Regulator-provider collaboration (Philippines, Malaysia) New e-finance laws and guidelines to m-fs providers (Korea) Clear licensing of non-bank m-fs (Malaysia, Korea) IT & AML supervision capacity (Philippines) AML/CFT training (South Africa)
12 KYC/CDD 12 HOW TO UNDERSTAND AND INTERPRET THE FATF CDD/KYC STANDARDS: Under Rec. 5, customer should be identified and his identity verified FATF allows reduced CDD/KYC measures (not full exemption of CDD/KYC) in circumstances when low risk can be PROVEN A Risk Assessment can be used to prove cases of low risk, which would merit reduced CDD/KYC measures Full exemption of CDD/KYC for certain financial activities (not specific financial transactions) is only permitted if: (I) policymakers are able to prove that the risk is low i.e. they can demonstrate that specific and unique circumstances around the activity generate a low level of ML or TF risk and, (ii) that they are able to provide evidence in that respect
13 KYC/CDD (cont d) 13 THE CURRENT CHALLENGE: Customers do not have the relevant identification and/or verification documents required Flexibility accorded to KYC/CDD standards not always understood, leading to potentially overly restrictive AML/CFT regulations Countries have not tailored AML/CFT standards to the appropriate level of risk given low value and/or low risk transactions Policymakers feel lack of clarity/guidance on KYC/CDD from FATF, leading to misinterpretation of the standards
14 14 Document requirements in developing countries are more stringent than in developed countries Percentage of countries that require certain criteria to open an account Source: Financial Access Database
15 KYC/CDD (cont d) 15 OUR PROPOSED SOLUTIONS: 1. Expanding list of acceptable IDs or Permit the use of alternative IDs (that not necessarily bear a picture) 2. Exempting the verification phase (verification vs. identification) 3. Implementing progressive KYC approach : countries could envisage a tiered customer identification program, in terms of which a customer that can only provide minimal verification is restricted to basic services and can access higher levels of services after more comprehensive verification
16 KYC/CDD (cont d) 16 Gradual KYC scheme adopted by Moneybookers LTD, an internet payment provider in the UK Source: Word Bank
17 Agents 17 THE CURRENT CHALLENGE: Different approaches in ways AML/CFT regulations implemented in regard to agent regulation Uncertainty about agent AML obligations, including their Licensing and Regulation, Scope of their AML duties, Supervision and Internal Procedures Do agents needs to be regulated? Do they need to comply with AML/CFT and if so to what extent and how?
18 Agents (cont d) 18 OUR PROPOSED SOLUTIONS: Agents (Retailers) should not be regulated Under FATF standards, they are not required to be license or registered They are not the account providers They are not the outsourcee of the MNO in the sense of FATF Interpretation They act on behalf of the Account Provider Impossible to regulate and supervise thousands of agents (retailers) on a practical level Principle monitors all regulation and supervision of agents
19 Agents (cont d) 19 OUR PROPOSED SOLUTIONS (cont d): Agents should be covered by certain AML/CFT obligations Perform some AML/CFT checks including KYC on the customer Record keeping STRs to the Account Provider Duties should be specified between the agency agreement of the AP and the Agent
20 Agents (cont d) 20 OUR PROPOSED SOLUTIONS (cont d): Ultimate Legal Liability Ultimate Legal Liability lies on the AP KYA (Know Your Agent) Principal (Account Provider) held accountable for AML/CFT compliance of agents, including determining extent and scope of CDD/KYC requirements between AP and Agents Should perform KYC/CDD on agents prior to recruitment, fit and proper tests and ongoing monitoring and scrutiny (including on-site visits)
21 Agents (cont d) 21 Example of Countries where Providers Assume Liability for Agents In the Philippines, the e-money circular explicitly states that it is the responsibility of the institutions to ensure that their agents comply with all AML laws, rules and regulations. Section 4 (e) states the following: it is the responsibility of the electronic money issuers to ensure that their distributors/e-money agents comply with all applicable requirements of the Anti-Money Laundering laws, rules and regulations. Similar Situation found in Brazil, Colombia, Brazi and Peru. Exception currently only is Kenya, where the provider does not assume liability for its agents legally
22 Reporting Obligations 22 FATF Standards Financial Institutions are required to report suspicious activity to the FIU The Current Challenge Since Mobile Money involves multiple entities such as agents/retailers, there is uncertainty in terms of who should bear the final reporting responsibilities to the FIU Uncertainty in terms of scope and nature of information to be reported in the particular context of mobile money, including consumer communications data and need to respect consumer data privacy issues Our Proposed Solutions Agents should report suspicions to the AP AP should be responsible for reporting STRs to national authorities as they are the principal manager (and should be legally held responsible) for account records and transactions
23 Supervisory/Enforcement Responsibilities 23 FATF Standards R. 29: supervisors should have adequate powers to monitor and ensure compliance by financial institutions with requirements to combat ML/TF including the authority to conduct inspection The Current Challenge Mobile Banking is a new category of financial activity involving new types of players not familiar to supervisory agencies Confusion about who is the primary supervisor for MNOs Possible conflict between Agencies that hold supervisory responsibilities (Central Bank, Communications Commission and FIU) Complexity of supervision for cross-border transactions and crossborder mobile remittances
24 24 Supervisory/Enforcement Responsibilities (cont d) Country Practices Many countries have chosen the Central Bank to be primary supervisory authority for mobile money Our Proposed Solutions There is more pros in favor of entrusting the Central Bank with responsibilities to regulate and supervise mobile money services Cons include: scarce human resources, limited budget, prudential arbitrage and
25 Supervisory/Enforcement Responsibilities 25 (cont d) Whoever is the primary supervisor: Supervisors need to be entrusted with the same responsibilities and allowed to carry the same tasks as for any type of financial institution Supervisors should be allowed to conduct onsite visits including telecom companies Supervisors should also have access to personally identifiable information that includes name, copy of IDs, and other related documents, M-Money account balance and correspondence
26 26 World Bank Policy Recommendations for National Authorities: Balance compliance burden with actual risks Low risk low value products (accounts, payment and remittance services) Adopt risk-based and tiered approaches to regulation / supervision Foster public / private dialogue to ensure practicality, proportionality of regulation / supervision Clarify some thorny issues in relation to Agents, Supervision, STRs obligations, consumer protection Promote formal financial services by reducing the comparative advantage of informal / unregulated providers Simplified identification requirements including on verification Creativity in and tailoring of CDD requirements (types of identifiers for instance)
27 27 World Bank Policy Recommendations for The Industries Industry to engage in dialogue with national authorities to shape policy and regulations Establish clear contractual arrangements between mobile providers and their retailers that clearly delineate breakdown of AML duties Provide ongoing training to their staff as well as their retailers Establish effective internal control mechanisms to trace suspicious activities through mobile money channels
28 Thank you Pierre-Laurent Chatain Wameek Noor Najah Dannaoui 28
Integrity in Mobile Financial Services
Integrity in Mobile Financial Services Workshop on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Bangkok, Thailand June 24-26, 2008. Raul Hernandez -Coss Financial Sector Specialist
More informationAssessment of AML/CFT in the Particular Context of Financial Inclusion
Assessment of AML/CFT in the Particular Context of Financial Inclusion AFI, SBS Peru and WB Forum, Lima Peru, May 12-13 2011 Pierre Laurent Chatain Lead Financial Sector Specialist (Financial Systems)
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 informationMONEY LAUNDERING AND TERRORISM FINANCING IN THE CORPORATE SERVICE PROVIDERS SECTOR. Domestic Trends
MONEY LAUNDERING AND TERRORISM FINANCING IN THE CORPORATE SERVICE PROVIDERS SECTOR Domestic Trends 31 May 2016 AGENDA ML/TF Trends National Risk Assessment Findings Sector Vulnerabilities Shell companies
More informationfinancial intelligence centre REPUBLIC OF SOUTH AFRICA Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre
Financial Intelligence Centre FAIS Workshop Presented by The Financial Intelligence Centre 3 December 2013 Agenda The FIC Functions of the FIC Value Chain FIC - 2012/2013 in review Compliance framework
More 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 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 informationStrict implementation of laws, improving vigilance and enhancing due diligence
Session I: Better communication and understanding of CFT challenges Strict implementation of laws, improving vigilance and enhancing due diligence European Union Middle East and North Africa Private Sector
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 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 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 informationJC/GL/2017/ September Final Guidelines
JC/GL/2017/16 22 September 2017 Final Guidelines Joint Guidelines under Article 25 of Regulation (EU) 2015/847 on the measures payment service providers should take to detect missing or incomplete information
More informationThis course is presented in London on: March 2018, October The Banking and Corporate Finance Training Specialist
Anti Money Laundering - Financial Crime Compliance Blockchain Technology, De-Risking And Money Laundering In the Financial Services Sector - (Banks & Non Banks) This course is presented in London on: 19-20
More 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 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 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 informationBANCO NACIONAL ULTRAMARINO, S.A. Anti-Money Laundering and Combating the Financing of Terrorism Disclosure Statement
BANCO NACIONAL ULTRAMARINO, S.A. Anti-Money Laundering and Combating the Financing of Terrorism Disclosure Statement 1. Institutional Information Name: Banco Nacional Ultramarino, S.A. (BNU) Head Office
More informationImplementing FATF standards in developing countries and financial inclusion: Findings and guidelines. Executive summary May 2008
Implementing FATF standards in developing countries and financial inclusion: Findings and guidelines Executive summary May 2008 Authors: Hennie Bester Doubell Chamberlain Louis de Koker Christine Hougaard
More informationCUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY
CUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY MCB SRI LANKA OPERATIONS 2017 Version 2.0 For Internal Use Only Document Control Sheet Title Of
More informationTHE GAZETTE PUBLISHED BY AUTHORITY
THE LIBERIA OFFICIAL GAZETTE PUBLISHED BY AUTHORITY VOL. XVI. Friday, May 10, 2017 NO.25 E X T R A O R D I N A R Y The Government of the Republic of Liberia announces that the Central Bank of Liberia (CBL),
More informationPublic Conference The fight against Money Laundering and Terrorist Financing Brussels, 15 March 2013
Public Conference The fight against Money Laundering and Terrorist Financing Brussels, 15 March 2013 14.30 15.45 Session 3 : Future challenges for the AML/CFT framework John Hogan, Head of Banking Directorate,
More informationCUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY (2012)
CUSTOMER DUE DILIGENCE (CDD) & ANTI-MONEY LAUNDERING (AML) / COMBATING FINANCING OF TERRORISM (CFT) POLICY (2012) Version: 1.1.1 Date of Revision: 30-Oct-2012 Compliance and Controls Group Page 1 INTRODUCTION:
More informationTECHNICAL PAPER: A risk-based approach to AML/CFT inspections Prepared by Council of Europe Expert Ms Maud Bokkerink
Project against Money Laundering and Terrorist Financing in Serbia MOLI Serbia DGI(2013) 29 September 2013 TECHNICAL PAPER: A risk-based approach to AML/CFT inspections Prepared by Council of Europe Expert
More informationAnti Money Laundering - Financial Crime Compliance
Anti Money Laundering - Financial Crime Compliance Blockchain Technology, De-Risking And Money Laundering In the Financial Services Sector - (Banks & Non Banks) This course is presented in London on: 30-31
More informationDialogue with the Private Sector
Dialogue with the Private Sector Chairman s Summary of Outcomes from the FATF Private Sector Consultative Forum, Vienna, 20-22 March 2017 Vienna, 22 March 2017 The Financial Action Task Force (FATF) held
More informationF o l l o w - Up R e p o r t. Anti-money laundering and counter-terrorist financing measures. Uganda
F o l l o w - Up R e p o r t Anti-money laundering and counter-terrorist financing measures Uganda 2 nd Enhanced Follow Up Report and Technical Compliance Re-Rating September 2018 1 The Eastern and Southern
More informationAdequate balance between AML/CFT regime and Financial Inclusion policy Mexican Experience. May 2011
Adequate balance between AML/CFT regime and Financial Inclusion policy Mexican Experience May 2011 Context In the last years, Mexico has been involved in a financial inclusion process. According to a World
More informationIntroduction to AML/CFT in New Zealand
Introduction to AML/CFT in New Zealand What You Will Learn This will give you a very quick overview of what AML/CFT is, how it impacts Cryptopia, and introduces you to the concepts you ll be hearing a
More informationPromoting Responsible Financial Inclusion: A Risk-based Approach to Supporting Mobile Money Transfer Services Expansion
Presentation Promoting Responsible Financial Inclusion: A Risk-based Approach to Supporting Mobile Money Transfer Services Expansion Seattle, Washington 29 October 2010 Table of Contents Promoting Financial
More informationAnti-Money Laundering Policy
Page 1/4 Anti-Money Laundering Policy The objective of Anti-Money laundering procedures that Apsilon LTD ( the Company )implements is to ensure that customers engaging in certain activities are identified
More informationEAA issues guidelines on compliance of anti-money laundering and counter-terrorist financing requirements for the estate agency sector
EAA issues guidelines on compliance of anti-money laundering and counter-terrorist financing requirements for the estate agency sector (21 February 2018) Subsequent to the passing of Anti-Money Laundering
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 informationCircular to SFC s Registered Intermediaries. Financial Action Task Force on Money Laundering Non-cooperative Countries and Territories
Circular to SFC s Registered Intermediaries Financial Action Task Force on Money Laundering Non-cooperative Countries and Territories We wrote to you on 31 July 2001 about the work of the Financial Action
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 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 informationRegulatory Update on AML/CFT
Regulatory Update on AML/CFT Putting Risk-Based in AML: The Road Ahead Mr Stewart McGlynn Division Head Anti-Money Laundering and Financial Crime Risk Hong Kong Monetary Authority 25 September 2015 Disclaimer
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 and Combating the Financing of Terrorism in Certain SADC Countries. Focus Note 3: AML / CFT due diligence and related matters
Anti-Money Laundering and Combating the Financing of Terrorism in Certain SADC Countries Focus Note 3: AML / CFT due diligence and related matters Compliance & Risk Resources Prepared for FinMark Trust
More informationTHE GAZETTE PUBLISHED BY AUTHORITY
THE LIBERIA OFFICIAL GAZETTE PUBLISHED BY AUTHORITY VOL.XII Monday, July 29, 2013 NO.48 E X T R A O R D I N A R Y The Government of the Republic of Liberia announces that the Central Bank of Liberia (CBL),
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 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 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 informationRegistry General September 2015
Registry General September 2015 1 Charities Compliance Officer Training Topics What is FATF? How FATF relates to charities Guidance Notes on the Charities (Anti-Money Laundering, Anti-Terrorist Financing
More 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 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 informationFINAL DRAFT RTS UNDER ARTICLE 45(6) OF DIRECTIVE (EU) 2015/849 JC /12/2017. Final Report
JC 2017 25 06/12/2017 Final Report On Draft Joint Regulatory Technical Standards on the measures credit institutions and financial institutions shall take to mitigate the risk of money laundering and terrorist
More informationAnti Money Laundering - The road to effectiveness. Thursday, 29 November 2012 Reykjavik, Iceland Special Adviser RUNE GRUNDEKJØN
Anti Money Laundering - The road to effectiveness Thursday, 29 November 2012 Reykjavik, Iceland Special Adviser RUNE GRUNDEKJØN 2 Agenda Introduction FATFs new 40 on the road to effectiveness Effectiveness
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 informationDUE DILLIGENCE QUESTIONNAIRE Anti-Money Laundering & Anti-Terrorist Financing
DUE DILLIGENCE QUESTIONNAIRE Anti-Money Laundering & Anti-Terrorist Financing This questionnaire is designed to provide Commercial Bank INTESA SANPAOLO ROMANIA SA with information about you, and your policies
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 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 / CFT Anti-money laundering and countering financing of terrorism. Designated Business Group Scope Guideline Updated in December 2017
AML / CFT Anti-money laundering and countering financing of terrorism Designated Business Group Scope Guideline Updated in December 2017 Guideline to reporting entities to assist the decision on whether
More informationFINANCIAL ACTION TASK FORCE. Mutual Evaluation Fourth Follow-Up Report. Anti-Money Laundering and Combating the Financing of Terrorism SPAIN
FINANCIAL ACTION TASK FORCE Mutual Evaluation Fourth Follow-Up Report Anti-Money Laundering and Combating the Financing of Terrorism SPAIN 22 October 2010 Following the adoption of its third Mutual Evaluation
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 informationتعليمات مكافحة عمليات غسل الا موال وتمويل الا رهاب لشركات التمويل
إدارة التفتيش البنكي Saudi Arabian Monetary Agency Banking Inspection Department تعليمات مكافحة عمليات غسل الا موال وتمويل الا رهاب لشركات التمويل ذو الحجة ١٤٢٩ ه Anti-Money Laundering and Counter-Terrorism
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 informationEurofinas is entered into the European Transparency Register of Interest Representatives with ID n
Eurofinas observations on the Commission s Proposal for a Directive on the prevention of the use of the financial system for the purpose of money laundering and terrorist financing (COM(2013) 45 final)
More informationIssues Paper. Part I. General Issues and Inherent Challenges with the Proportionality Principle
GPFI 1 st Annual Conference on Standard- Setting Bodies and Financial Inclusion: Promoting Financial Inclusion through Proportionate Standards and Guidance Basel, October 29, 2012 Introduction Plenary
More informationThis is the published version de Koker, Louis 2013, The 2012 Revised FATF Recommendations: Assessing and Mitigating Mobile Money Integrity Risks Within the New Standards Framework, Washington Journal of
More informationExecutive Summary. A. Key Findings
Executive Summary 1. This report provides a summary of the anti-money laundering and combating the financing of terrorism (AML/CFT) measures in place in Portugal as of the date of the on-site visit (28
More informationSupranational risk assessment on money laundering and terrorist financing (SNRA) DG Justice and Consumers B3 Financial crime Kallina SIMEONOFF
Supranational risk assessment on money laundering and terrorist financing (SNRA) DG Justice and Consumers B3 Financial crime Kallina SIMEONOFF Disclaimer This presentation represents the views of the author
More informationMONEY-LAUNDERING PREVENTION SANTANDER GROUP GLOBAL POLICY
MONEY-LAUNDERING PREVENTION SANTANDER GROUP GLOBAL POLICY August 2007 INDEX 1. Introduction 2. The concept of money laundering 3. Written anti-money laundering program 4. Customer acceptance policy 5.
More informationANTI-MONEY LAUNDERING PROCESS MATURITY
ANTI-MONEY LAUNDERING PROCESS MATURITY NEPAL BANKING INDUSTRY Survey Report 2017 Survey Partner AML PROCESS MATURITY - NEPAL BANKING INDUSTRY Survey Report 2017 Anti-Money Laundering (AML) and Combating
More 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 informationOverview of AML/CFT Framework of
Overview of AML/CFT Framework of The ISLAMIC REPUBLIC OF IRAN Feb 2013 2 TITLES 1. Legal-institutional framework on AML/CFT 2. Executive measures, Statistics, facts and figures 3. International Co-operation
More informationArticle 1. Article 2. Article 3 A FCM shall comply with the following provisions in undertaking CDD measures:
Chinese National Futures Association Guidelines for Anti-Money Laundering and Countering Terrorism Financing for Futures Commission Merchants (Template) Article 1 Passed in the 11th Joint Session of 3th-term
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 informationDerisking: Implications for AML/CFT Regime. Dakar, Senegal August 2017
Derisking: Implications for AML/CFT Regime Dakar, Senegal August 2017 1 Topics 1. Concept of de-risking 2. Consistency of derisking with the FATF standards 3. Why some financial institutions de-risk 4.
More informationMUHAMMAD AMER RIAZ SECURITIES (PVT) LIMITED KNOWYOUR CUSTOMER (KYC) ANDCUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES
MUHAMMAD AMER RIAZ SECURITIES (PVT) LIMITED KNOWYOUR CUSTOMER (KYC) ANDCUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES Document ID KYC/CDD Title Know Your Customer (KYC) and Customer Due Diligence
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 informationEQUITY MASTER SECURITIES (Pvt.) LIMITED KNOWYOUR CUSTOMER (KYC) AND CUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES
EQUITY MASTER SECURITIES (Pvt.) LIMITED KNOWYOUR CUSTOMER (KYC) AND CUSTOMER DUE DILIGENCE (CDD) POLICES AND PORCEDURES Know Your Customer(KYC) and Customer Due Diligence (CDD) policies and procedures
More informationAnti-Money Laundering and Countering the Financing of Terrorism SECTOR RISK ASSESSMENT
Anti-Money Laundering and Countering the Financing of Terrorism SECTOR RISK ASSESSMENT Securities Commission New Zealand Level 8, Unisys House 56 The Terrace P O Box 1179 WELLINGTON 6140 Email seccom@seccom.govt.nz
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 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 informationFATF Report to the G20 Finance Ministers and Central Bank Governors
FATF Report to the G20 Finance Ministers and Central Bank Governors April 2019 The Financial Action Task Force (FATF) is an independent inter-governmental body that develops and promotes policies to protect
More informationAnti-money laundering and countering the financing of terrorism the Reserve Bank s responsibilities and approach
Anti-money laundering and countering the financing of terrorism the Reserve Bank s responsibilities and approach Hamish Armstrong Taking action to reduce money laundering and the financing of terrorism
More information3 IDENTIFICATION MEASURES: OVERVIEW
3 IDENTIFICATION MEASURES: 3.1 OF SECTION 1. This section explains the identification measures required under Article 13 of the Money Laundering Order, and the framework under which a relevant person is
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 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 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 informationAPPLICATION PAPER ON COMBATING MONEY LAUNDERING AND TERRORIST FINANCING
APPLICATION PAPER ON COMBATING MONEY LAUNDERING AND TERRORIST FINANCING OCTOBER 2013 About the IAIS The International Association of Insurance Supervisors (IAIS) is a voluntary membership organization
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 informationPolicy and regulatory challenges of microinsurance market development in Africa
Ad-Hoc Expert Meeting on CAPACITY-BUILDING FOR THE INSURANCE SECTOR IN AFRCA 23 February 2009 Policy and regulatory challenges of microinsurance market development in Africa by Ms. Martina WIEDMAIER-PFISTER
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 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 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 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 informationGOOD PRACTICES ON THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING IN THE NOTARIAL SECTOR
GOOD PRACTICES ON THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING IN THE NOTARIAL SECTOR 2018 1 INDEX Contents 1. INTRODUCTION... 3 2. PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING
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 informationMutual Evaluation Report of Malaysia September Way forward for Labuan IBFC
Mutual Evaluation Report of Malaysia September 2015 - Way forward for Labuan IBFC by Iskandar Mohd Nuli Senior Director, Supervision & Legal Department October 7, 2015 at Grand Dorsett Hotel Labuan Introduction
More informationSwaziland Country Report. Finalised by: Compliance & Risk Resources
AML/CFT and Financial Inclusion in SADC Consideration of Anti-Money Laundering and Combating the Financing of Terrorism Legislation in Various Southern African Development Community (SADC) countries Swaziland
More informationMONEY-LAUNDERING AND TERRORISM FINANCING PREVENTION SANTANDER GROUP GLOBAL POLICY
MONEY-LAUNDERING AND TERRORISM FINANCING PREVENTION SANTANDER GROUP GLOBAL POLICY June 2010 1 CONTENTS 1. Introduction 2. The concept of money laundering 3. Written anti-money laundering program 4. Customer
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 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 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 Developments. Jersey Financial Services Commission
Anti Money Laundering Developments Basel Committee Andrew Le Brun, Director International and Policy Jersey Financial Services Commission Basel guidance Protect: Safety and soundness of banks Integrity
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 informationMoney Laundering and Terrorist Financing Risks in the E-Money Sector
Money Laundering and Terrorist Financing Risks in the E-Money Sector Thematic Review TR18/3 October 2018 TR18/3 Contents 1 Introduction 3 2 Overview 5 3 Findings 7 Annex 1 Glossary 16 How to navigate this
More informationAML/CFT and Financial Inclusion in SADC
AML/CFT and Financial Inclusion in SADC Consideration of Anti-Money Laundering and Combating the Financing of Terrorism Legislation in Various Southern African Development Community (SADC) countries Botswana
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 information