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Financial Crime and Compliance Masterclass Including CTF & AML

An essential overview of FCC/AML and sanctions risks, along with effective mitigation techniques for managing and reducing them.

Awesome view of a popular tourist destination Supertree Grove at Gardens by the Bay in Singapore

A one-day AML CTF course

Part One

Introduction

  • This CTF training course assesses recent high-profile fines
  • Recent Regulatory Action
  • What is the FCC?
  • What is AML?
  • The scale of the problem
  • What is CTF?
  • The 'Rules'
  • What are financial institutions required to put in place? An overview
  • What is CDD, KYC, IDV?
  • Who is responsible for FCC Compliance?

Who Sets the Rules & Who Publishes Best Practice Guidelines?

  • FCA
  • UN
  • EEC
  • The USA – OFAC
  • Best Practice Guidelines:
    • FATF
    • Wolfsberg Group
    • Transparency International
    • JMLSG
    • Egmont Group

What Must Institutions Do to Comply?

  • The FCC Cycle – several key stages
  • Risk-Based approach
  • Material Trigger Events
  • The current three lines of defence model
  • Staff training and competence
  • Transaction Monitoring; the critical “safety net”

Sanctions – Brief Overview

  • Who sets them and why are they set?
  • Who is impacted?
  • What are they?
  • OFAC and the US dimension
  • When should the screening take place?
  • 'In Flight' Screening
  • Other screening
  • Case Study/Example

Counter/Anti-Terrorist Financing

  • A different management challenge – why?
  • Following the money
  • Dormant accounts
  • The scale of the problem
  • Effective controls
  • Informal Value Transfer Systems
  • Charities / Non-Profit Organisation
  • Screening processes
  • Case Study/Example

How Money Laundering is Carried Out in Practice: Examples

  • Smurfing
  • Co-mingling
  • Additional Bank Accounts
  • Using property and other assets
  • Complex Money Laundering
  • Under and Over Invoicing
  • 'Phantom' transactions
  • Quality and quantity manipulation
  • Asset Management
  • Fine Art
  • Near money instruments
  • Attempting to circumvent client identification requirements

Part Two

Essential Control Mechanisms

  • Customer Due Diligence
  • KYC; getting to know the customer
  • IDV; checking what they say
  • EDD and DDD
  • Source of Wealth
  • Source of Funds
  • Ultimate Beneficial Ownership
  • PEP’s
  • Effective escalation process
  • Transaction monitoring
  • Behavioural Monitoring with 'Swim Lines' (Subject to cost constraints and complexity)
  • Remediation process
  • Exit and mitigation process
  • Review process
  • Oversight process using a 3LOD model
  • AML CTF Compliance Training Case Study/Example

Politically Exposed Persons

  • Definition – formal
  • Definition in practice
  • Why are they a special case?
  • Mandatory high risk
  • UBO issues
  • Source of Wealth issues
  • Annual Review issues
  • Domestic/Local PEPS
  • Case Study/Example

Specific Identification & Verification Issues

  • Trust nominee and fiduciary accounts
  • Corporate vehicles
  • Client accounts opened by professional intermediaries
  • Non-face-to-face customers
  • Correspondent banking – KYC requirements and Due Diligence
  • Offshore clients
  • Case Study/Example

Suspicion & Escalation

  • What must banks have in place?
  • An effective escalation process
  • Concern versus Suspicion the Four D’s
  • The role of the MLRO
  • Communication lines
  • Suspicious Activity Reports / Suspicious Transaction Report
  • Whistleblowing
  • Case Study/Example

High-Risk Products & Services

  • Movement of monies
  • Movement of value
  • Speed of movement
  • Other material parties make/receive value
  • Anonymity of parties
  • Use of 3rd party channels
  • Cross border movement
  • Access to cash or cash equivalent instruments
  • Internet Casinos
  • Prepaid Cards and E-Cash
  • Case Study/Example

Other Key Issues & Open Forum Talking Points

  • AML policies and procedures; What is the difference and why are they important?
  • Probability of an offence crystallising
  • Understanding the difference between KYC, ID&V and CDD
  • Profiling customers – what does it mean?
  • Building and using trigger events in practice
  • What do you do if you are suspicious?
  • Recognising and handling suspicious transaction reports
  • Human factors in money laundering risk management

Redcliffe Training’s AML CTF courses are delivered by an expert who experienced a highly successful, long and varied “fast track” career in Lloyds Bank. Leading him to a very senior management position in the bank’s Corporate Banking Division at an early age, he was “head-hunted” to join a merchant bank at the board director level. He now has over 40 years of experience in the UK banking and financial services sector.

Alongside the delivery of Redcliffe’s AML CTF training course, our expert has enjoyed a freelance career since retirement. As a Compliance, FCC & AML training consultant and currently an external Master Trainer at both HSBC and Bank of China, you’re in capable hands.

At HSBC he has been a leading member of their global FCC & AML training programme which is now entering its seventh year. He has created and delivered sessions to a vast range of clients, from global giants to small firms and partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, USA, South America, Europe, Africa, Asia and the Middle East.

He is highly adaptive, hands-on and a sought-after facilitator who always receives excellent feedback. Alongside expertise in Compliance, FCC & AML, the trainer is adept in risk management, trade finance and all major aspects of corporate, private and retail banking. He is also a highly experienced soft skills trainer and has completed numerous “train the trainer” assignments.

This CTF workshop will cover the following:
  • The regulatory and best practice requirements necessary to combat FCC.
  • Be fully conversant with the mandatory risk-based approach, and how it is created and managed alongside the controls it drives.
  • Become familiar with how AML Regulations impact a very wide range of firms.
  • Appreciate the need for a holistic approach to FCC and the importance of ensuring it becomes part of ‘business as usual’.
  • Managing the customer journey throughout the process to ensure compliance does not become unpleasant or a deal-breaker.
  • Why it is important to persuade staff at all levels to take this seriously and discharge duties effectively.
  • AML CTF training ensures an understanding of how money laundering is carried out and how to put in place effective mitigants and controls.
  • Recognise that key components to an effective FCC process are sound judgement and common sense: plus a full understanding of the rules so when decisions have to be made, they are appropriate and most effective.

  • Redcliffe Training is a market leader in AML CTF compliance training.
  • We have been the primary training supplier to two of the world’s largest banks for several years and as such, the subject is a core competency for us.
  • The course director is an acknowledged subject matter expert and a Master Trainer in both FCC and Risk Management at the world’s biggest trade finance bank.
  • We don’t use academics at Redcliffe. All our trainers are practitioners achieving at least senior management status over lengthy careers.
  • Our course leader has been in the industry for over 40 years and was a former main board director of a London-based merchant bank.
  • This AML CTF training course is packed full of real-life case studies and discussion sessions with delegate involvement encouraged at all times.
  • We are judged solely by our results and are proud to say feedback from delegates over many years is always excellent.

FCC and AML are currently a very high-profile risk, with Regulators punishing firms who fail to implement adequate systems and controls; even though no money laundering or sanctions breaches occurred. As such, AML CTF courses are a ‘must know’ for everyone working in a firm that is subject to the rules.

Financial Crime Compliance and Regulatory Compliance will be a ‘top risk’ for nearly every Financial Institution. In recent times, Regulators have criticised many leaders in the Financial Services sector for not having appropriate and/or effective risk mitigation procedures in place. There have also been some eye-watering fines for non-compliance.

AML CTF training has never been more apparent with financial institutions required to focus increasingly on Financial Crime Prevention measures alongside robust combative systems. This includes detailed policies, clear lines of defence, solid CDD processes, a risk-based approach, clear accountabilities, and above all, effective staff training and awareness throughout the organisation.

None of this is difficult. It is, however, costly, and time-consuming and involves putting in place procedures and systems to deter, detect and protect the institution from being used by criminals.
Who Should Attend?
Anyone with an interest in the topic.
Methodology
This highly interactive CTF workshop is packed full of real-life case studies and discussion sessions.

  • The instructor provided so much context for everything that was covered in the course and it was obvious he had many years of experience in working with fin crime. I really enjoyed all the true story examples he mentioned and also how interactive the course was even though it was on Zoom. Really great!
  • This was an excellent performed course...This will help us to make more precise governance over our AML frameworks. I must say The trainer and the way he held the whole course... The knowledge he has and the way he is presenting it is just amazing. I liked the cases and the magnitude of how huge it all is and then the presentation related to the banks with governance, KYC and the other parts.
  • I had great expectations because my company informed me that this was a very highly prestigious course. This course met my overall expectations. I think the course from an AML and CTF perspective was fantastically well mediated.
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