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23 Cards in this Set
- Front
- Back
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What should an AML program establish? |
Minimum standards for the organization that are reasonably designed to comply with applicable laws and regulations |
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What is on the most important steps in creating a good AML compliance program? |
Assessing specific risks of ML and terrorist financing |
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Characteristics of a risk-baed approach |
Flexible - Effective - companies better equipped than legislators to assess and mitigate ML and terrorist financing risks Proportionate - promotes a common sense and intelligent approach |
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Risk categories |
Prohibited High-Risk Medium-Risk Low- or Standard-Risk |
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High-risk customer types |
Casinos Offshore corporations Banks in tax/banking havens Leather goods stores Currency exchange houses, money remitters Check cashers Car/boat/plane dealerships User car/truck dealers Travel agencies Securities brokers/dealers Jewel/gem/precious metals dealers Import/export companies Cash-intensive businesses |
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High-risk banking functions and products |
Private banking Offshore international activity Deposit-taking facilities Wire transfer and cash-management Undisclosed primary beneficiary Loan guarantee schemes Travelers checks Official bank checks Money orders Foreign exchange Trade-financing w/ unusual pricing features Payable-Through-Accounts |
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Elements of an AML Program |
System of internal policies, procedures, controls Designated compliance officer w/ day-to-day oversight over the AML program Ongoing employee training program Independent audit |
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What should internal controls do |
Enable the compliance officer to recognize deviations from standard procedures and safety protocols |
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Role of the AML Compliance Officer |
Responsible for designing and implementing the program, making necessary changes and disseminating information about the program's successes and failures to key staff members, constructing AML related content for staff training programs and staying current on legal and regulatory developments |
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Basic elements of compliance training |
Who to train (based on needs) What to train on How to train When to train Where to train |
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Basic factors in AML training |
General information Legal framework Penalties How to react How to respond Internal policies Legal recordkeeping requirements Suspicious transaction reporting requirements CTR requirements Duties and accountability of employees |
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Who has ultimate responsibility for AML compliance program |
Board |
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Board's roles in AML compliance |
Reviewing and approving the overall AML program and ensuring that there is ongoing oversight |
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Elements of a sound CDD program |
Customer ID, including source of funds/wealth Transaction/activity profiles of anticipated activity Definition and acceptable of customers in the context of specific products and services Customer/account risk assessment and grading Account/transaction monitoring Investigation/examination of unusual activity Documentation of findings |
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Identification elements for new customers |
Legal name Permanent physical address Phone numbers/email address Date/place of birth national Occupation/employer Identification Signature |
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Methods of verifying customer identity |
Confirming birthday from official document Confirming permanent address Callback to customer Confirming validity of official documentation |
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Identification elements for corporate entities |
Name of institution Principle place of operations Mailing address Names of primary authorized users Contact phone numbers Form of official identification Certificate of Incorporation Resolution of Board for account Nature/purpose of business |
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Methods of verifying corporate entity |
Copies of latest report and accounts Inquiry by service or confirmation of documents Company search Independent information verification process Prior bank references Physical visit Callback |
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Requirements when identifying an OFAC match |
Block/reject transaction Notify OFAC |
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What does a Know Your Employee program do |
Allows institution to understand an employee's background, conflicts of interest and susceptibility to money laundering complicity |
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Elements of a suspicious reporting process |
Procedures to identify suspicious activity Formal evaluation of each instance and continuation of unusual activity Documentation of the reporting decision, whether or not filed with the authorities Procedures to periodically notify senior management or board of suspicious activity filings |
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Indicators of money laundering |
ATM usage (excessive usage) Moving customers (frequent moves) Opening deposits/investments (source of funds) Out-of-Market Windfalls Credit balances Common addresses/phones/IP addresses/data |
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Technology uses in AML program |
Transaction monitoring Watch list filtering Automation of regulatory reporting Detailed audit trail |
