AML & CTF New Entrant Programme
Suitable for any firm with AML responsibilities like Estate Agents etc
The UK is one of the world’s largest and most open economies, whose strength is built on extensive and productive relationships across the globe. Ministers have the responsibility for national security and financial services, so they want the UK to continue to be an attractive country for legitimate business and a leading global financial centre. But they also recognise that the UK’s openness and status as a global financial centre exposes it to the risk of illicit financial flows.
Money laundering and terrorist financing are significant threats. Recent terrorist attacks in London, Manchester and elsewhere highlight the importance of the fight to deprive terrorists of the resources they need. Serious and organised crime has been estimated to cost the UK tens of billions of pounds every year. That is why we must continue to crack down on dirty money, strengthening the UK’s security and prosperity as well as that of our partners overseas.
What Makes Compliance Consultants Courses Different?
- for over 20 years and have a first class reputation for delivering excellent value-for–money training
- Our consultants are practicing compliance specialists and have industry qualifications and many years experience
- This is a core competence for us and we are certain nobody trains more effectively than we do when it comes to this topic
- The course director is an acknowledged subject matter expert and is also a Master Trainer
- The workshop involves real life case studies and discussion sessions, with delegate involvement encouraged at all times
- We don’t use academics as trainers. All our trainers are experienced practitioners who achieved at least senior management status over long careers
- Your course director has been in the industry for over 30 years and has owned and/or operated financial services consultancies
- We are judged solely by our results and we are proud to say that delegate feedback over many years has always been excellent
Objectives
- Appreciate why AML & CTF are important
- Understand how to complete an initial risk assessment
- Appreciate the importance of effective controls and oversight
- Recognise what an effective process should look like
- Understand what “good” client on-boarding looks like
- Realise that CDD is a process not just a tick box exercise
- Recognise the importance of embedding CDD into the business as a normal business procedure as swiftly as possible
- Recognise that business should never be taken on at the expense of compliance
- Conversely, that compliance should not become just a business blocker
Course Content
- What is AML?
- The £40Bn scale of the problem
- Why does it matter?
- The three stages of money laundering
- The three lines of defence model
- Customer due diligence
- KYC, CDD, EDD & DDD
- A,B, C & D obligations Customer due diligence measures
- High risk customers
- Sanctions
Who Regulates This?
- What must institutions have in place?
- Why is compliance important?
- Who sets the rules?
- Regulators
- BIS
- FATF
- Wolfsberg
- Transparency international
- JMLSG
- Who polices the rules?
- The US dimension
- Clear policies and procedures
- Senior management setting the tone
- The role of the Compliance Head and the MLRO
The UK’s Initial Risk Assessment and the Risk Based Approach
- Risk assessment methodology
- What services/products would be attractive to a criminal?
- Risk categories – standard, medium, high
- Key controls
- Sign off
- Intensity of CDD
- Review frequency
- Transaction monitoring
- The review process
- Trigger events
- The 3 lines of defence working as a team
- Case study/Example
CDD, KYC, IDV, EDD & DDD – What do These Mean?
- The financial crime lifecycle
- CDD – the process
- KYC – getting to know the client
- IDV – checking the facts independently
- EDD – for higher risk relationships
- DDD – For some categories of client/counterparties
- Source of Wealth
- Source of Funds
- Anti Terrorist Funding
- The review process
- Trigger events
- The 3 lines of defence working as a team
- Case study/Example
Dealing with Non-Personal Entities or Challenging Relationships
- PEPS& Associates
- Public Officials
- What is a non-personal entity
- Corporates
- Trusts
- Charities
- Not for Profit Organisations
- Money services business
- Offshore relationships
- Transparency – ensuring you have an end to end view
- Ultimate beneficial ownership – 25% or 10%
- Non face to face clients
- Overseas clients
- Jurisdictional risk
- Case study/Example
Sanctions
- What are they?
- Who sets them?
- Who can be sanctioned?
- Zero tolerance
- Sanction types
- Comprehensive/country
- List based
- Activity based
- Sanction screening
- Onboarding
- Review
- Payments
- Real time (in-flight) versus non real time
- Commercial providers –Worldcheck, Oracle
- Sanction alerts
- Sanction breaches
- Payment stripping
- Re-submits
- Case study/Example
AML Typologies
- How is money laundering completed in practice
- “Professional” criminals want to stay under your radar
- Placement risk easier to manage
- Layering is a bigger vulnerability
- Smurfing
- Co-mingling
- Multi banked
- Overpayments
- Underpayments
- Changing quality and quantity
- Other common methods
- Case study/Example
Transaction Monitoring – The Safety Net
- Swim- lines and alerts
- Who generates alerts & why?
- What should prompt an alert?
- Doesn’t make sense
- Doesn’t fit our knowledge of the client
- Doesn’t fit in with normal business activity
- You have a bad feeling/misgivings
- First line alerts
- Second line alerts
- Sanction alerts
- Alert options
- Accept
- Seek more information
- Escalate immediately
- The importance of getting more information where applicable
- Balancing the risk of tipping off with information gathering
- Case Study/Example
Escalation Process
- SAR’s or an internal intermediate stage – the pros and cons
- Methods of escalation
- Direct to MLRO
- Via line manager
- Via a confidential email
- Whistleblowing
- Essential SAR information
- What does the MLRO do with alerts?
- When must we involve specialist sanctions colleagues?
- Deciding to escalate to the NCA
- Time limits for escalation
- Personal and potentially criminal liability of all parties
- What happens once an SAR has been raised?
- What happens next?
- The mitigation process
- The exit process
Other Key issues
- Staff training – must be risk based
- Creating a holistic, not process-based regime
- Embedding escalation into “business as usual” processes
- False positives
- Ensuring the level of escalations are appropriate to the profile of the business
- The role of internal audit
- The MLRO report
- Checking it all works well
- Senior and top management oversight
- Case study/Example
Course Conclusion
Wrap up
Summary
Open Forum
Background of the Trainer
Course Director
Lee has worked with a range of organisations from smal start-ups through to FTSE100 companies, including foreign banks and institutions, many that have had difficulties identifying and managing compliance risk, and helped them develop effective, robust systems. He has adapted his experience to develop this course and supporting materials with the practical skills based focus. Lee’s skills, qualifications and experience make him ideal for supporting anyone wishing to develop top-class knowledge in the management of Anti-Money Laundering and Counter Terrorist Financing.
Course Summary
As a new entrant to either the financial services industry or other businesses required to have in place effective AML & FCC controls, the range of requirements and responsibilities can seem overwhelming. There is also a danger of thinking AML is the only, or at least the biggest risk facing a firm. This is not true but it is a very high profile risk and the consequences of poor management or failure are very severe in both reputational and financial penalty terms. The MLR2017 has widened the scope considerably for AML procedures so that virtually all cash or near cash handling institutions have a responsibility to prevent financial crime.
At the heart of a successful AML process is a risk assessment, leading to a risk-based approach and a clear system for on-boarding new clients as well as reviewing existing relationships. This workshop style, highly interactive course describes what “good” looks like, how to achieve it and how to understand why it is such an important feature of corporate governance.
Who Should Attend
Anyone with an interest in the subject especially “Relevant persons” under the UK MLR 2017, i.e. Estate Agents etc;
- Where previously only holders of a casino operating licence were covered by the regulations, they now pertain to all gambling providers
- Trustees now have greater obligations in relation to revealing the beneficiaries of trusts
- Those engaging in financial activity on ‘an occasional or very limited basis’ are not covered by the regulations. ‘Occasional or very limited’ is defined as:
- annual turnover from financial activity of less than £100,000 (this figure was previously £64,000)
- activity limited to transactions not exceeding EUR 1000 per customer
- financial activity ancillary to a larger business
- financial activity not more than 5% of the total turnover of the larger business
- financial activity only offered to customers of the main business
Knowledge Pre-requisites
None required
from £250 pp – Minimum 5 persons
Format
- Duration is as a full day classroom workshop – Your Venue or we can arrange local venue at additional cost.
- Attendees can also purchase our AML & CTF Policy & Procedures Document at 50% discount
Call us on 0207 097 1434
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