:Module One
Anti-Money Laundering (AML) From A Regulator’s Perspective
?Is AML Compliance Different From Regular Compliance
Understanding The Different Requirements
a) Financial Action Task Force (FATF)
b) USA Patriot Act
c) Treasury/Securities and Exchange Commission (SEC)
The Role Of The Regulator In AML Compliance
a) What you can and cannot expect of banks and other institutions in the reporting chain
b) Educating the market
Partners To Enforcement
a) Financial Services Authority (DFSA)
b) AML and Suspicious Cases Unit (AMLSCU)
c) Middle East and North Africa Financial Action
Task Force (MENAFATF)
a) US Government, SEC, Secret Service and Treasury
AML In The Introducing-Clearance Context Forfeiture Of funds In US Interbank Accounts
:Module Two
AML From An Institution’s Perspective
Enterprise-Wide AML: Looking At The Whole Picture
a) AML at branch offices
b) Outsourcing issues
c) Mergers and Acquisitions (M&A)
Suspicious Activity Monitoring, Detection And Reporting
a) Definition of suspicious activity
b) Banks and financial institutions required to file Suspicious Activity Reports (SARs)
c) The gatekeeper initiative – G-8 finance ministers attempt to require professionals to file SARs
d) When and where to file SARs
e) Safe harbor from civil liability for filing SARs
Protection from reporting possible criminal activity
a) Examples of penalties and fines for failure to file SARs
b) Examples of penalties and fines for improperly filing SARs
c) Identification And Verification Of
Accountholders
a) Minimum requirements
b) Determining validity of information received
c) Determining source of funds
d) Politically Exposed Persons (PEPs)
:Module Three
AML From The Customer’s Perspective
Changing Customer Workload – Passing On Compliance Workload To The Customer
a) Origination and sources of funds – what is right to ask?
b) Keeping client confidentiality – is there a conflict of interest?
c) The legal perspective and precedents
Dealing With Transactions Of The Super-High-Net-Worth
Additional Requirements For US Transactions And Customers
Group Exercise
:Module Four
Some AML Legislation Affecting The Global Markets
GCC Legislation
a) EU, Asia, Africa
- Example: Saudi Arabia’s Consultative Council approved 29 articles of anti-money laundering legislation
b) UAE legislation
Authorized Disclosures And Failure To Disclose
a) Appropriate consent
b) Recent cases and penalties
c) Role of the enforcer and the regulator
d) Recent changes in legislation (including the EU’s 3rd AML directive)
:Module Five
Implementing AML Initiatives In Your Organization
Ensuring AML Efforts Satisfy Regulators
a) Monitoring risks
b) Implementing a risk-based AML program
Strategies For AML Success
a) Integrated approach
b) Treat AML as an ongoing process, not an IT solution
c) Choose integrated IT solutions
d) Training employees
:Group Exercise
Review And Program Summary
Final Examination
Multiple-Choice format.