Risk Based Approach to Anti-Money Laundering (AML) & Combating Terrorist Financing (CTF)
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Day 1 Setting the Stage: Anti-Money Laundering and Combatting Terrorist Financing Basics Current international cases, fines, and legal judgments AML/CTF success stories Corporate and economic implications of AML/CTF Key terms, definitions, and institutional differences Legal and regulatory background to AML/CTF The Money Laundering Process Placement, layering, and integration Red flags: unique to each business line Relationship to terrorist financing and blocked assets Roles: who’s responsible for what? Terrorist Financing Operations Funds generation Transactions Legal and illegal means Relationship to money laundering Case Study and Simulation Exercise 1: Delegates will, through review of a case, be assigned roles (customers, business line, middle and back office, compliance and legal, regulators) to analyze transaction data for possible money laundering activity/terrorist financing, escalation, reporting, investigating, and resolution) Where It All Starts: The AML and CFT Rubric: Establishment The Anti-Money Laundering and CFT Program Design of an AML/CTF Policy Effective Elements of the AML/CTF Program Policy Identifying the Effective Elements Designation of an AML and CTF Compliance Officer (s) Auditing for AML and CTF: internal and external Ongoing training Due diligence and customer identification Scenario, control, and systems testing Supervision Reporting and information flow: suspicious activity reports Surveillance, systems, and investigations Staffing, credentials, experience, and characteristics Escalation Record keeping Day 2 Combating Terrorist Financing CTF Goal: to aggressively identify, escalate and deter terrorist organizations’ funding and transactions networks FATF Recommendations FATF Global Money Laundering and Terrorist Financing Threat Assessment (GTA) Risk Assessment Methodologies FATF: Inclusion vs Exclusion CTF Resources Intelligence analysis Sanctions administration Enforcement Financial regulatory action Policy expertise Implementation and Application of the Rubric Policies, Procedures, and Controls: Implementation Designation of an AML Compliance Officer Auditing for AML: internal and external Ongoing training Due diligence Customer identification Supervision Reporting and information flow: suspicious activity reports Surveillance, systems, and investigations Staffing, credentials, experience, and characteristics Escalation Record keeping Risk Based Approach Geography and country risk Business risk Product risk Reputational risk Transaction risk Client risk Process risk Suspicious Activity Reporting Trigger areas Information flows Preventing terrorist financing through AML Case Study and Simulation Exercise 2: Response to Regulatory Review and Implementation of Follow Up Measures. Delegates will simulate A) regulator’concluding a review of a faulty AML Programme at a mid-sized financial institution and B) the financial institution’s response to the AML review and sanctions Danger Zones: Failures AML/CTF compliance policy Faulty testing Unsatisfactory training and non-compliance with training requirements Insufficient resources: systems, technology, and staff Lack of follow up: connect the dots Organizational Settings Laws, rules and regulations International organizations Information sharing Industry organizations Forensic Review of Surveillance and Investigation Dissecting an AML/CTF Investigation A day in the life of an AML/CTF surveillance team Identification of red flags Business line specific AML/CTF issues Technology and AML/CTF: technology-based schemes, and technology-based monitoring, surveillance, and detection Day 3 Know Your Customer Best Practices Policy statement Rationale Customer identification programme Application of the customer identification programme Covered customers Data collection: individuals, institutions, official/governmental organizations Verification: documentary vs non-documentary Logical consistency Additional measures Lack of verification Data from external financial institutions Service providers High risk accounts Special Topics Shell banks Politically exposed persons Correspondent banks and foreign banking relationships Enhanced due diligence Identity theft Charitable organizations Volume Monitoring Customer Relationships Consistency Pattern analysis Systems Aggregation College knowledge vs flagrant indifference Risk rating Monitoring credit relationships AML/CTF IN Practice: Implications for Business Lines Internet gambling Insurance fraud Tax evasion Wire transfers Check collection Funds transfer and money transmittal Card dystems Currency and monetary systems Class Exercise and Simulation 3: Development of an AML Program Policy Round Robin: AML/CTF and Sanctions Regulation Development Course summary and close
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