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Financial Crime and Compliance Masterclass Including CTF & AML

An essential overview of FCC/AML & sanctions risks with mitigation techniques that can be used to manage and reduce them

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

A one-day course

AML CTF Training Course: Part One

Introduction

  • 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 and 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?

  • This AML CTF course looks at 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

Examples of How Money Laundering Carried Out in Practice

  • 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

AML CTF Training Course: Part Two

Essential Control Mechanisms

  • Customer Due Diligence
  • KYC – getting to know the customer
  • IDV – checking what they say
  • EDD & 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
  • 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 SuspicionThe 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 CTF training explores 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 – 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’s anti-money laundering course is delivered by an expert who had a highly successful, long and varied “fast track” career in Lloyds Bank. This led him to a very senior management position in the bank’s Corporate Banking Division at an early age. He was then “head hunted” to join a merchant bank to head the main board director-level risk function. He now has over 40 years of experience in the UK banking and financial services sector.

He has been a freelance Compliance, FCC & AML training consultant since retiring and is currently an external Master Trainer at both HSBC and Bank of China. 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 training 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.

This AML CTF course trainer is a highly adaptive, hands-on and highly sought-after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience, from “black belts” to novices. As well as his Compliance, FCC & AML specialism, his expertise includes but is not limited to 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.

  • Anti-money laundering compliance training explores the regulatory and best practice requirements necessary to combat FCC.
  • Be fully conversant with the mandatory risk-based approach, how it is created, how it is managed and the controls that it drives.
  • How AML Regulations now 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 that compliance does not become unpleasant or a deal-breaker for them.
  • How important it is to persuade staff at all levels to take this seriously and discharge their duties effectively.
  • Understand how money laundering is carried out in practice to put in place effective mitigants and controls to prevent it.
  • Recognise that the key components to an effective FCC process are sound judgement, common sense and 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 FCC and AML CTF training. We have been the primary supplier of trainers to two of the world’s largest banks for several years. This is a core competency for Redcliffe and when it comes to this topic; we are certain nobody trains more effectively than we do.
  • The course director is an acknowledged subject matter expert and is also a Master Trainer in both FCC and Risk Management at the world’s biggest trade finance bank.
  • We don’t use academics as trainers. All our trainers are practitioners who achieved at least senior management status over long careers. Our course director 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 and delegate involvement is encouraged at all times.
  • We are judged solely by our results and we are proud to say that delegate feedback over many years has always been 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, this financial crime prevention and anti-money laundering compliance course is 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.

Financial institutions are required to focus increasingly on Financial Crime Prevention measures and must have robust systems in place to combat them. This includes detailed policies, clear lines of defence, robust CDD processes, a risk-based approach, clear accountabilities and above all effective staff training and awareness throughout the organisation.

None of this is difficult. However, it is costly and time-consuming. It 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

Highly interactive AML CTF training packed full of real-life case studies and discussion sessions.
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