Course Content

Basic AML/ CFT Concept And Regulatory Responses
Understanding Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)
The historical background and general introduction
Basic elements and concepts of AML/CFT
Understanding & Responding to Suspicious Transactions & Activities
Understanding predicate offences
The regulatory framework
Legislative Pronouncements (global and locally)
Duties and obligations of stakeholders and professionals in AML/CFT regime.

AML/CFT Implementation Beyond Regulatory Compliance: A Risk Management Strategy
Indicators and red-flags to suspicious transaction – suspicious activities
Appropriate reporting – response to suspicious transaction/activities
Compliance monitoring – basic requirements and how to monitor compliance
The risk exposure of AML/CFT to individuals, entities, the nation and the globe
Mitigations strategies to the risk exposure
Identifying the challenges to effective AML/CFT implementation.

AML/CFT and Financial Institutions

  • Deposit Money Banks
  • Insurance Firms
  • Capital Market
  • Bureau De Change
  • Finance Houses
  • International Finance Institutions
  • Compliance issues

FOR WHOM?

CROs

Chief Compliance Officers

Risk Managers

Internal Auditors

ERM Heads/Managers

Treasurers

 

 

 

 

Module 1: Introduction

  • 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

 

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 of AML/CFT

Module 2

  • 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

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

  • 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

Module 3

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


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


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 systems
  • Currency and monetary systems

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