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DescriptionCourse Overview: This course will provide you with a full update on the European Union’s 4th Money Laundering Directive (“4th MLD”) and will enable you to be ready to implement the new law when it comes into force imminently. The 4th MLD will be covered in detail under all the relevant topic headings, as set out below. For those based outside the EU, the 4th MLD represents the latest global best practice in AML / CFT and will therefore be of equal relevance to all countries. It will also be of direct relevance to all sectors, not just those within the Financial Services sector. This course will highlight the relevance to different sectors from the principles, practices and authorities discus…
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Day 1 Anti money laundering (AML) and counter financing of terrorism (CFT) – Origin and definitions – Latest issues globally – Risks and impact on banks and the financial services industry – Risks and impact on other industry sectors within the Regulated Sector – Placement, layering and integration techniques Global compliance issues – The FATF and its regional groups – The “40 + 9” Recommendations – The new revised FATF Recommendations 2012 – Globalisation and the need for international regulation and cooperation – Inter-relationship with Anti Bribery & other anti financial crime compliance Definition and objectives of KYC – The history of the KYC requirement – Definition of a customer/client – Developing the customer’s transaction profile – Importance and rationale of KYC KYC standards and regulatory requirements – The legal and regulatory framework – Compliance programme – Customer acceptance policy – Customer identification and verification – General identification requirements – The role of: – Supervisors and managers – Auditors – Senior management and directors Application of KYC – The AML policy, guidelines and manual – Guidelines for opening accounts and establishing relationships – Conducting Customer Due Diligence (CDD) – Conducting Enhanced Due Diligence (EDD) – Changes in relation to beneficial ownership Workshop A: Case studies on current trends and methods of money laundering and financing of terrorism. Workshop B: Devising ways to detect and prevent one’s institution from being used to facilitate money laundering and financing of terrorism. Day 2 Procedure for customer identification – Identification procedure at different stages – Establishing banking relationship – When carrying out a financial transaction – Customer research and verification – When bank doubts authenticity or veracity or the adequacy of previously obtained customer identification data – Proof of identity – Establishing identity and establishing present residential address – Developing the customer’s profile – KYC for existing account-holders – Confidentiality of information collected under KYC Specific identification issues – Minor accounts – Trust, nominee and fiduciary accounts – Joint accounts – Corporate vehicles such as Special Purpose Vehicles (SPVs) – Introduced business – Client accounts opened by professional intermediaries – Politically exposed persons (PEPs) – Beneficial Ownership – Non face-to-face customers (example, through internet and electronic banking) Adopting a risk based approach – Requirements under the legal framework – Impact of the new 2012 FATF Recommendations – Assessing vulnerabilities and risk – Full KYC vs. Risk-based KYC – Why and when to conduct CDD and EDD – When to implement reduced KYC requirements – Reliance on KYC done by third parties, agents or intermediaries Constructing the AML and KYC framework – Group policies – Risk assessments – Roles and responsibilities – The MLRO – Requirement of integrity of all employees – Training and awareness – Monitoring and record keeping – Reporting requirements – Threshold reporting and Suspicious Transaction Reporting (STR) or “SARs” – Dealing with the authorities and enforcement agencies – Audit – Role of HR, training, risk, IT and other critical departments – Management Information (MI) and oversight Implementing and managing the total KYC – Evaluation of employees in ensuring integrity – Due diligence – Record keeping – On-going training – Monitoring - Reporting Real life case-studies of KYC management – KYC failures and success – Ways to prevent such failures – Tips for successful implementation – Meeting expectations Workshop A: How to conduct customer due diligence for individual customers and small businesses and how to develop these customers’ profiles. Workshop B: How to conduct customer due diligence for corporate customers and trusts/nominees accounts and how to develop these customers’ profiles.