The Scale of the Problem

• What is financial crime?
• The size of the problem
• How has financial crime changed during the crisis
• Lessons from recent scandals
• What is “money laundering?”
• Anti-bribery and corruption
• Terrorist financing
• Tax transparency
• What really matters?

Case Study: What are the key considerations and concerns that your Board has with regard oo financial crime

The Global Response

• The FATF and its role
• The non-compliant country list
• The FATF recommendations
• Guidance on correspondent banking
• Risk based approach guidance for the securities sector
• Financing of recruitment for terrorist purposes
• Financial flows from human trafficking
• Concealment of beneficial ownership
• Money or value transfer services
• Virtual currencies
• Corruption
• Prepaid cards, mobile payments and internet-based payment services
• AML and financial inclusion
• BIS standards on money laundering deterrence
• The EU directives including the 5th directive
• Wolfsberg Principles
• Transparency International
• Developing policies

Case Study: What should be the key elements of AML deterrence policies and procedures?

Elements of a Risk Based Approach

• Assessing vulnerabilities and risk
• The Risk Matrix
• Customer due diligence
• Client take on
• Relying on the others and “equivalence”
• Monitoring people by staff and/or IT
• Reporting internal and to law enforcement/local authorities
• The role of the MLRO/Nominated Officer (NO)
• Management Information (M.I.) and oversight

Case Study: Applying risk assessment in practice

Constructing the Anti-Money Laundering (AML) Framework

• Policies
• Roles and Responsibilities
• Senior Management and M.I. requirements
• The MLRO/NO (or equivalent) challenge!
• Risk Assessments and Procedures
• Training and Awareness
• Warning signs
• Monitoring and record keeping
• Data mining
• Reporting and dealing with the authorities
• Review and evaluation

Case Study: Compare AML frameworks – what really works?

Applying a Risk-Based Approach

• Complications of PEPs
• Enhanced due diligence
• Offshore “situations” and issues
• Due diligence (on-going)
• Record keeping
• Training
• Monitoring
• Reporting
• Questions/Feedback/Discussion

Case Study: When is a Pep a PEP and what this is likely to mean. Practical documentation driven case study

Roles of Internal/External Audit, etc.

• The 3 lines model and financial crime deterrence
• Providing Assurance
• Adding Value
• A common understanding of risk
• Lessons from UK and global failures
• The contribution of H.R., Training, Risk, I.T. and others

Case Studies: Consider real cases and identify the actions that should have been taken.

International Sanctions

• The sanctions regime
• Sectoral sanctions
• The UN and EU and local legislation
• Purposes of Sanctions
• Sanctions risks
• Linkage to ML and other financial crime

Case Study: Dealing with warning signs

Terrorist Financing

• What is a terrorist?
• Nature of financial activity
• Warning signs to look out for
• Types of business which might be a concern
• Where is information available?
• Additional activity required
• Building an appropriate structure
• Conducting the investigation

Case Study: Develop a series of warning signs to identify terrorist financing concerns

The US Dimension

• Extra territoriality- US PATRIOT ACT
• OFAC and Enforcement
• FCPA, bribery and corruption

Case Study: Review examples of US cases – what went wrong?

Session 10:   Financial crime and data mining 

• Structured vs. unstructured data
• The challenge of data mining and financial crime
• Opportunities
• Non-statistical approaches
• Understanding and using the psychology of financial crime
• Common indicators
• A data mining framework
• Detecting and combating money laundering activities
• Data mining and fraud detection
• Data mining and other types of financial crime
• Tax evasion
• Corruption
• Insider dealing, market abuses
• Using the results of Data Mining for investigations and prosecutions 

Case Study:  Where is data mining of greatest importance?  Who should be responsible for undertaking this work?

By the conclusion of this course delegates will have gained not only a thorough understanding of the nature of financial crime regulation, risks and obligations but as importantly learned the mitigating controls and how to action them within a bank, specifically

• What money laundering and terrorist financing really are.
• The techniques used by money launderers and terrorist financiers
• The rules and regulations applying and the issues relating to suspicion and reporting.
• The role of sanctions and sanctions risk
• The key elements of the risk-based approach
• The control structures they would wish to employ in their bank.
• The role of data mining and the value it can add
• The role of warning signs
• How to deal with concerns

All delegates completing the course will receive a personalised, dated Risk Reward CPD accredited Certificate in the Implementation of Money Laundering, Sanctions & Financial Crime Deterrence Mitigation in Banks.

Highly interactive expert-led intensive presentation, Q&A, group real-time in-depth case studies, regulation and discussion supported by key principles and theory.

The virtual learning platform uses safe, industry preferred encrypted Cisco WebEx to optimize live face-to-face visual interaction, discrete chat, for polling and quizzes.

(An invitation via email with access link is included for all participants.)