Key texts
4th Money Laundering Directive & Fund Transfer Regulations
UK Money Laundering Regulations
Proceeds of Crime Act 2002
FCA’s FC guidance
FATF Recommendations and assessments
JLMSG
5th Money Laundering Directive
Money Laundering, Terrorist Financing and Sanctions
Proceeds of Crime Act offenses – concealment, arrangements facilitates acquisition, use or retention, acquires or possession, failure to report, tipping off
Overall risk management – identify and assess risks of AML and terrorist finance, MI
Role of MLRO & Board members
UN and OFAC Sanctions
Formal policies and procedures
Client Due Diligence (CDD)
Simplified, client and enhanced due diligence – in theory and practice
Ongoing monitoring of transactions and review of client due diligence
Client, country and activity risk rating
Indicators of terrorist financing
Sanctions screening
Adverse Media Screening
Third party reliance
Expected account activity and monitoring against it
Identification of clients
On-boarding
Beneficial ownership and other controllers
Client types (e.g. individuals, corporates, trusts, etc)
Rules on Wire Transfers – labelling transactions
Source of wealth and specific funds
Danger areas
Distant transactions
Politically exposed persons, family members and close associates
Vulnerability of non-commercial bodies and public contracts
Correspondent banking
Shell banks
Bearer securities
General issues with handling cases
Suspicious activity report (SARs) and suspicious transaction reporting (STR)
Review of ongoing relationship and client’s use of it
General issues
Whistleblowing
Training obligations
Employee selection issues
Reviews of password access and other IT security issues