Course Outline

1. Introduction to Money Laundering and Terrorist FinancingRole of the Financial Action Task Force (FATF) • 40 recommendations • Nine special recommendations • Proposed amendments and extensions • Mutual reviews • Non-co-operative countries and territoriesEU Directives • 1st and 2nd Directives and how they set the stage for the 3rd Directive • 3rd Directive • Other EU Directives which impinge on or supplement the requirements in respect of money launderingThe US Scene • History of the fight against money laundering • US Patriot Act • OFAC
2. Local Legal and Regulatory RequirementsCustomer Due Diligence • CDD requirements following a risk-based approach • Individuals • Legal entities • Beneficial owners • Face-to-face • Electronically • RemotelyOngoing Monitoring • For CDD reviews • Transaction monitoring • Risk indicatorsRecord Keeping • What records must be kept • How do you keep them and for how long • CDD records • Transaction recordsSuspicions and Reporting • What is suspicion? How do you identify it? • What internal reporting systems do you need? • What must you report to the authorities? • How do you report? • What records do you need? • When do you need consent? • How do you deal with a customer whilst awaiting it? • How do you handle a customer after a report has been made?Tipping Off • What is tipping off? • How do you avoid it?Money Laundering Reporting Officer (MLRO) • What are the duties? • What are the obligations? • Annual reportSenior Management Responsibility • Setting an AML policy • Audit of AML compliance Sanctions• Consolidated sanctions list • How do you apply it • License and recordsTraining and Awareness • Who and when to train • Level of training • Methods of training • Assessing competence • Training records • Maintaining awareness

Areas of Expertise