Life Assurance Association Cork 27 th April Financial Services Compliance & Training Ltd 1
|
|
- Grant Fields
- 7 years ago
- Views:
Transcription
1 Life Assurance Association Cork 27 th April 2010 Financial Services Compliance & Training Ltd 1
2 What does it feel like to work in Financial Services in 2010? Financial Services Compliance & Training Ltd 2
3 A bit like this. Financial Services Compliance & Training Ltd 3
4 SMILES. GO MILES! Financial Services Compliance & Training Ltd 4
5 Financial Services in 2010 Financial Services Compliance & Training Ltd 5
6 The New Central Bank of Ireland Financial Services Compliance & Training Ltd 6
7 The New Central Bank of Ireland Governor of the Central Bank, Mr Patrick Honohan Head of Financial Regulation, Mr Matthew Elderfield Financial Services Compliance & Training Ltd 7 *
8 Who is this.? Financial Services Compliance & Training Ltd 8
9 The Financial Services Ombudsman Mr Bill Prasifka Financial Services Compliance & Training Ltd 9
10 Anti Money Laundering Training Why? Financial Services Compliance & Training Ltd 10
11 Financial Regulator Requirement Application Process: Part 6. Question 6 Have all officers and employees of the applicant firm been made aware of their obligations under the IIA 1995 and the Criminal Justice Act 1994? Yes/No How did you answer this question? Financial Services Compliance & Training Ltd 11
12 Anti Money Laundering YES, otherwise you would not have been authorised! With YES comes responsibilities. Anti Money Laundering Staff Training is an Annual Requirement and This must be recorded on staff personnel records Financial Services Compliance & Training Ltd 12
13 What will I cover. Recent cases: Ireland & UK New Anti Money Laundering Legislation Changing role of the Financial Regulator Know Your Client: Customer Due Diligence The offence of Money Laundering Identification Exemptions Enforcement Offences and the Consequences Financial Services Compliance & Training Ltd 13
14 Ireland Northern Bank cases Indictable case attracting huge media attention Cunningham case: 2.3 million, sale of gravel pit to Bulgarian business man Financial Services Compliance & Training Ltd 14
15 Ireland Northern Bank cases Don Bulman (Dazman) Case: only concluded March 07found in possession of 94,000 (Feb 05), convicted IRA membership but not ML Connection not made to Northern Bank as cash in Euro s not stg Financial Services Compliance & Training Ltd 15
16 UK case Controls failures 29 October 2008 The Financial Services Authority (FSA) fined Sindicatum Holdings Limited (SHL) 49,000 and its money laundering reporting officer (MLRO), Michael Wheelhouse, 17,500 for not having adequate anti-money laundering systems and controls in place for verifying and recording clients identities. This is the first time the FSA has fined a money laundering reporting officer; he failed to implement adequate procedures for controlling money laundering risk Financial Services Compliance & Training Ltd 16
17 UK case continued No ML offence had been committed the firm failed to: implement adequate procedures for verifying the identity of its clients, this was reflected in client files keep adequate records of those identified "It is vital to the integrity of the UK s financial markets that regulated firms are not used by criminals to launder money. Senior management must implement and follow procedures that meet our requirements so that the risks their firms face are properly managed. Financial Services Compliance & Training Ltd 17
18 Criminal Justice Act... Anti Money Laundering What has all this to do with our business? Financial Services Compliance & Training Ltd 18
19 The Legislation Criminal Justice Act, 1994 Criminal Justice (Terrorist Offences) Act, 2005 Criminal Justice (Money Laundering) Bill 2008 will give effect to the 3 rd EU Anti Money Laundering Directive. Draft Guidance Notes March 2010 Financial Services Compliance & Training Ltd 19
20 Financial Regulator s current role Financial Regulator has been limited to making suspicious transaction reports to Fraud Intelligence Unit (FIU). Up until now AML has not been part of Financial Regulator s core mandate. Financial Regulator would have made reports to the Garda Síochána and Revenue Commissioners where suspicions arose of offences being committed under the CJA 94. Financial Services Compliance & Training Ltd 20
21 Reports to the Revenue Over 65,000 Reports received since May facilitated criminal prosecutions (Tax) 25 facilitated criminal investigations (Customs) Financial Services Compliance & Training Ltd 21
22 Reports to the Revenue 400 referred to CAB and Special Investigations 2,000 used in Audit and Compliance enquiries 300 cases settled with the Revenue 35m Financial Services Compliance & Training Ltd 22
23 Industry overview Fraud Intelligence Unit FIU FIUNet FIU FIUNet Competent Authority Competent Authority Credit institution s MiFID Firms Insurance companies Insurance Brokers Money transmitters Legal and accounts Advisors Cash dealers 15,000 Financial Services Compliance & Training Ltd 23
24 Financial Regulator s new role The new law will require the Regulator to use administrative sanctions to ensure credit and financial institutions establish AML infrastructures appropriate to combat the money laundering or terrorist financing risks posed by their businesses. Financial Services Compliance & Training Ltd 24
25 Financial Regulator s new powers Directive 37: gives the Regulator the power to Fine & Sanction firms and individuals where it observes a lack of: Customer Due Diligence Maintenance of Records Clear reporting lines Staff training: Continue Annual Training Requirement Financial Services Compliance & Training Ltd 25
26 3 rd EU Directive AML What will change for you? Customer Due Diligence (CDD) Risk Based Analysis: your professional instinct! Financial Services Compliance & Training Ltd 26
27 KNOW YOUR CLIENT (KYC) Financial Services Compliance & Training Ltd 27
28 Customer Due Diligence (CDD) What should I be doing now? CDD Risk Based Identify your customer and verify his/her/its identity using reliable, independent source documents, data or information Determine whether the he/she/it is acting on behalf of another person, and then taking reasonable steps to obtain sufficient identification data to verify the identity of that other person Identify the (ultimate) beneficial owner: understand the ownership and control structure of corporate customers. Financial Services Compliance & Training Ltd 28
29 Customer Due Diligence cont Consider whether you need to conduct enhanced due diligence with respect to higher risk categories. Decisions taken on establishing relationships with higher risk customers should be taken by senior management. Subject to national legal requirements insurers may apply reduced or simplified measures in the case of low risk categories. Be clear on the purpose and intended nature of new business relationships Financial Services Compliance & Training Ltd 29
30 Customer Due Diligence cont Conduct ongoing due diligence on customers and scrutinise transactions throughout the course of that relationship so as to check they are consistent with the your knowledge of the customer and his her its business and risk profile. This applies across the business lines: General & Life That firms keep transaction records secure for five years (Financial Regulator documents 6 years) Electronic Storage now provided for (55(4) wholly or partly in an electronic, mechanical or other non-written form only if they are capable of being reproduced in a written form. Financial Services Compliance & Training Ltd 30
31 Day to day impact MLRO in place AML Procedure in Office Procedures Manual Annual training requirement Staff members know what to watch out for? Staff know the risk profile of your customers? Is simplified due diligence or enhanced due diligence possible / required in some instances? Financial Services Compliance & Training Ltd 31
32 The Offence of Money Laundering Process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities. If undertaken successfully, money laundering enables criminals to legitimise dirty money by mingling it with clean money, ultimately providing a legitimate cover for the source of income Financial Services Compliance & Training Ltd 32
33 Stages and Methods of Laundering Money Placing Layering Integration Tax Evasion Financial Services Compliance & Training Ltd 33
34 Stages and Methods of Laundering Money Placement - illegitimate funds (normally cash) find their way into the financial system via payment into legitimate accounts Layering - used to disguise the audit trail between the funds and the original point of entry into the system by using numerous transactions to move the funds globally through various financial products and institutions in an effort to disguise their origins Financial Services Compliance & Training Ltd 34
35 Stages and Methods of Laundering Money Integration - where funds are reintroduced as legitimate wealth to fund further activities or the acquisition of assets Tax evasion Deposit Accounts & Single Premium Policies Financial Services Compliance & Training Ltd 35
36 Issues to Focus On Client more interested in encashment penalties than potential returns Why? Requesting the return of funds that have been held in suspense pending receipt of adequate documentation, like ID, they have changed their mind! Product Producers monitor instances where termination of policies by clients in the cooling off period: this could impact on you risk based analysis. Payments for insurance products by cheque with a typo in name on cheque account and/or proposer Bank Holiday urgency of new business, manipulation of staff Customers who will only deal with a specific member of staff Clients moving funds in and out of a policy at the cost of early withdrawal penalties Financial Services Compliance & Training Ltd 36
37 Client Identification Procedures Each Firm must determine and implement its own policy Original* or certified copy of ID documents (passport/ driver s licence) should be obtained. The new Bill has an extensive list of alternative acceptable identification documents. Certified by a member of the Gardai, a certified/ chartered accountant, a practising solicitor, public notary or embassy/ consular staff Financial Services Compliance & Training Ltd 37
38 Client Identification Procedures When meeting the customer face to face the copies of identity documents and supporting evidence should be retained and marked originals sighted, signed and dated. It is unacceptable to certify a photocopy of the above without sight of the original Financial Services Compliance & Training Ltd 38
39 Verify Address Original or certified copy of one of the following must be obtained (full list is more extensive): Utility Bill (gas, electricity, telephone, etc) Bank, Building Society, Credit Card Statement Recent original Mortgage Statement Tax Notices from Revenue Social Welfare Documents House/Motor Insurance Certificates Financial Services Compliance & Training Ltd 39
40 Company Verification Original or certified copy of one of the following must be obtained for an Irish Registered Company: Certificate of Incorporation Memorandum & Articles of Association AND/OR Document giving named individual authority to act on the company's behalf AND Recent Report & Accounts Financial Services Compliance & Training Ltd 40
41 Partnership Verification Original or certified copy of one of the following must be obtained for an Irish Registered Partnership: Certificate of Registration of Business Name Partnership Agreement AND/OR Document giving named individual authority to act on the partnerships behalf AND Recent Report & Accounts Financial Services Compliance & Training Ltd 41
42 Record Keeping Originals or copies admissible in legal proceedings. Evidence of identity = 5 years after relationship ends. Transaction records = 5 years after date of execution of the last transaction. Capable of retrieval without delay: Certificate of Identification signed on proposal, where is the ID, cannot locate General FR requirement to keep records for 6 years (Statute of Limitations period). Financial Services Compliance & Training Ltd 42
43 EXEMPTIONS Deminimis Amounts Layering Method of Payment Exemptions A Pensions Policy Financial Services Compliance & Training Ltd 43
44 When is Identification required? Identification need only be sought where: The annual premium exceeds 900 or in the case of single premium business, the relevant amount is 2,300 and The premium is not being paid by means of a cheque or a direct debiting mandate or other transfer from an account held in the name of the policyholder with another designated body in a Member State of the EU or a state or country prescribed by the Minister The policy in question is other than a pension s policy taken out by virtue of a contract of employment or the occupation of the person to be insured under the policy provided that the policy does not contain a surrender clause and may not be used as collateral for a loan. This will apply to Revenue approved pensions. Financial Services Compliance & Training Ltd 44
45 Reporting Suspicious Transactions Report suspicions of money laundering to MLRO: Do not discuss any suspicion with colleagues, as this information may filter back to the customer and constitute the offence of tipping off. Once you have made a report to the MLRO, and this report has been acknowledged, then the employee has fulfilled their duty. Reporting of suspicion to the Garda Siochána and the Revenue Commissioners at discretion of MLRO. Employees should familiarise themselves with Examples of Suspicious Transactions in Appendix B2 of Guidance Notes. Financial Services Compliance & Training Ltd 45
46 FRAUD ENFORCEMENT When in doubt make the report to Garda/Revenue 11,145 Money Laundering reports received by the Garda Bureau of Fraud Investigation in 2008 Profile of a Fraudster: 85% Male 70% aged between % of cases investigated were occasions where the employee had visited the fraud on their employer Source: Eugene Gallagher, Detective Superintendent, Garda Bureau of Fraud Investigation. Financial Services Compliance & Training Ltd 46
47 ENFORCEMENT The Financial Regulator will report to the Garda Siochana and the Revenue Commissioners where it suspects that firms are not adhering to the Money Laundering Guidance Notes Financial Services Providers which become involved in a money laundering scandal risk prosecution and loss of their market reputation Financial Services Compliance & Training Ltd 47
48 Offences and Penalties BOTH THE FIRM AND THE EMPLOYEE CAN FACE CRIMINAL PENALTIES FOR FAILURE TO COMPLY WITH THE LAW Financial Services Compliance & Training Ltd 48
49 Key Offences Criminal Penalties (Directive 37 Fines & Sanctions) Money Laundering Assistance 14 Years Imprisonment Reporting Procedures 5 Years Imprisonment Tipping off Training Financial Services Compliance & Training Ltd 49
50 In Summary Educate yourself Customer Due Diligence Do not compromise your integrity Monitor activities Report suspicions Retain records 3 rd EU AML Directive Financial Services Compliance & Training Ltd 50
51 THANK YOU for your kind attention Evelyn Hanrahan Financial Services Compliance & Training Ltd 51
Anti Money Laundering. Cork. Fergus Bradley November 2011
Anti Money Laundering Cork Fergus Bradley November 2011 Program Objectives Define Money Laundering Understand Corporate & Personal responsibilities i Define some Best Practices Keep up to date with changes
More informationAnti Money Laundering. Cork. Fergus Bradley Jan 2014
Anti Money Laundering Cork Fergus Bradley Jan 2014 Agenda Focus on key obligations of AML Review CBI industry feedback Look at practical steps in AML in business Incorporate CJA Act 2013 implications CBI
More informationANTI-MONEY LAUNDERING POLICY AND GUIDANCE NOTES
ANTI-MONEY LAUNDERING POLICY AND GUIDANCE NOTES MARCH 2016 CONTENTS PAGE Policy SADC Anti-Money Laundering Policy Statement 3 Money Laundering Guidance Notes Background 5 Treasury Management 6 Miscellaneous
More informationFederal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector 1
English is not an official language of the Swiss Confederation. This translation is provided for information purposes only and has no legal force. Federal Act on Combating Money Laundering and Terrorist
More informationREGULATION FOR LIFE INSURANCE AND FAMILY TAKAFUL INSURANCE BUSINESSES ON PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM
REGULATION FOR LIFE INSURANCE AND FAMILY TAKAFUL INSURANCE BUSINESSES ON PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM (unofficial English translation) REGULATION FOR LIFE INSURANCE AND FAMILY
More informationING DIRECT Customer Identification Procedures for Brokers
ING DIRECT Customer Identification Procedures for Brokers Managing obligations of the Anti-Money Laundering and Counter-Terrorism Financing Act ( AML/CTF Act ) for the purpose of Customer Identification
More informationANTI-MONEY LAUNDERING POLICY. Introduction
ANTI-MONEY LAUNDERING POLICY Introduction This Policy outlines how the University and its employees will manage money laundering risks and comply with its legal obligations under the Proceeds of Crime
More informationOn the prevention of the use of the financial system for the purpose of money laundering and terrorist financing PART II
Guidance Notes On the prevention of the use of the financial system for the purpose of money laundering and terrorist financing PART II SECTORAL GUIDANCE - Life Assurance September 2012 Version 8 1 1 Scope...
More informationAnti-Money Laundering and Counter- Terrorism Financial Policy
Anti-Money Laundering and Counter- Terrorism Financial Policy Version: March 2014 1. INTRODUCTION...3 2. DEFINITIONS...3 3. RISK-BASED APPROACH...3 4. AML COMPLIANCE OFFICER...4 5. SUSPICIOUS TRANSACTION
More informationSettlement Agreement between the Central Bank and Western Union Payment Services
Settlement Agreement between the Central Bank and Western Union Payment Services Ireland Limited Central Bank of Ireland imposes fine of 1,750,000 in respect of Anti Money Laundering and Countering the
More informationNational Solidarity Bond Frequently Asked Questions Issue 3
1. What is the National Solidarity Bond? 2. Who can purchase the National Solidarity Bond? 3. What is the minimum & maximum amount needed to purchase the Bond? 4. Do I get paid annual interest on the National
More informationGuidance Notes. Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010. Part II SECTORAL GUIDANCE NOTE.
Guidance Notes on compliance with the Criminal Justice (Money Laundering and Terrorist Financing) Act, 2010 Part II SECTORAL GUIDANCE NOTE for CREDIT UNIONS January 2013 1 Version 2 ILCU Contents A. WHAT
More informationPrudential International
For Adviser use only Prudential International Anti Money Laundering (AML) Requirements Guide for New Business,Top ups and Payments Out > Anti Money Laundering (AML) Requirements New Business and Top-ups
More informationMONEY LAUNDERING GUIDANCE NOTES FOR STOCKBROKERS
MONEY LAUNDERING GUIDANCE NOTES FOR STOCKBROKERS Issued with the Approval of the Money Laundering Steering Committee February 2004 INDEX Paragraphs Section 1 Background What is Money Laundering? 1-3 Scope
More informationADVANCED ANTI-MONEY LAUNDERING COURSE. Course Notes
ADVANCED ANTI-MONEY LAUNDERING COURSE Course Notes Course Provider: Course: Riliance Training Limited Advanced Continuing Professional Development (CPD) The person undertaking this course has been awarded
More information(unofficial English translation)
REGULATION ON PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM FOR MONEY TRANSFER BUSINESSES AND MONEY CHANGING BUSINESSES (unofficial English translation) REGULATION ON PREVENTION OF MONEY LAUNDERING
More informationMONEY LENDERS. Sector Specific AML/CFT Guidance Notes. May 2015
MONEY LENDERS Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not be relied upon
More informationStates of Jersey Police & Customs Joint Financial Crimes Unit. Guide to compiling a Suspicious Activity Report (SAR)
States of Jersey Police & Customs Joint Financial Crimes Unit Guide to compiling a Suspicious Activity Report (SAR) 1. Introduction 1.1. This document has been produced to assist compliance and money laundering
More informationSENATE LEGAL AND CONSTITUTIONAL AFFAIRS COMMITTEE QUESTIONS ON NOTICE TO ATTORNEY-GENERAL S DEPARTMENT
SENATE LEGAL AND CONSTITUTIONAL AFFAIRS COMMITTEE QUESTIONS ON NOTICE TO ATTORNEY-GENERAL S DEPARTMENT RESPONSE TO QUESTIONS ON NOTICE BY SENATOR LUDWIG [Second set of Questions for 22 November 2005] Senator
More informationGUIDANCE NOTES FOR SOLICITORS ON ANTI-MONEY LAUNDERING LEGISLATION
GUIDANCE NOTES FOR SOLICITORS ON ANTI-MONEY LAUNDERING LEGISLATION OBLIGATIONS ARISING UNDER EU DIRECTIVE 2001/97/EC, THE CRIMINAL JUSTICE ACT, 1994 AND THE CRIMINAL JUSTICE ACT, 1994 (SECTION 32) REGULATIONS,
More informationRegulatory procedures manual for anti-money laundering for insurance companies, brokers and agents
Capital Market Authority Sultanate of Oman Po Box: 3359, Pc: 112 Tel 00698 24823100, Fax 00968 24816691 Web: www.cma.gov.om, e-mail: info@cma.co.om 1. Introduction: Money laundering and terrorism financing
More informationMTN Mobile Money 2012
MTN Mobile Money 2012 Anti-Money Laundering It is the policy of MTN to prohibit and actively prevent the use of its money transfer services to facilitate money laundering, the funding of terrorists or
More informationKnow Your Customer (KYC), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
Know Your Customer (KYC), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) Vanessa Read, Acting Head AML Supervision Christiane Chidiac, Manager AML Supervision Agenda Introduction KYC Principles
More informationText of the Recommendation and Interpretative Notes
1 of 5 FATF Recommendation 5: Customer due diligence and record-keeping Text of the Recommendation and Interpretative Notes See also: The full text of the 40 Recommendations and interpretative notes Return
More informationThe proposed Fourth Money Laundering Directive
The proposed Fourth Money Laundering Directive What the proposed Directive means and how to keep your business safe USING IDENTITY INTELLIGENTLY Money Laundering Directive What the proposed Directive means
More informationNOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM - BANKS
MAS 626 2 July 2007 Last revised on 1 July 2014 (Refer to endnotes for history of amendments) NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING AND COUNTERING
More informationMoney Laundering The Legal Position Andrew Campbell University of Leeds a.campbell@leeds.ac.uk
Money Laundering The Legal Position Andrew Campbell University of Leeds a.campbell@leeds.ac.uk Introduction Why is this important? Most of us will now be covered to some extent by the anti money laundering
More informationDr. Nicholas Ryder Professor in Financial Crime Department of Law
Money laundering and the United Kingdom: a haven for dirty money and an endless cycle? A critical reflection on the United Kingdom s anti-money laundering policies Dr. Nicholas Ryder Professor in Financial
More informationTHE NOTARY AND MONEY LAUNDERING. Paper. Presented to a Meeting. The Faculty of Notaries Public in Ireland. (Friday 12 November 2010) Dr Eamonn G Hall
THE NOTARY AND MONEY LAUNDERING Paper Presented to a Meeting Of The Faculty of Notaries Public in Ireland (Friday 12 November 2010) By Dr Eamonn G Hall Director of Education Faculty of Notaries Public
More informationGeneral Investment Conditions Ireland. The important information you need to know about opening and maintaining your account.
General Investment Conditions Ireland The important information you need to know about opening and maintaining your account. January 2016 General Investment Conditions Ireland The important information
More informationPART 3 The Basics 10
PART 3 The Basics 10 PART 3 The Basics A. What is Money Laundering? 3.1 Put simply, money laundering covers all kinds of methods used to change the identity of illegally obtained money (i.e. crime proceeds)
More informationAnti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Guide for small financial adviser businesses
r PAGE Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) Guide for small financial adviser businesses In this guide you will find: Who is this guide for?... 3 What does this guide do?...
More informationAnti-money laundering guidance for solicitors undertaking property work
Anti-money laundering guidance for solicitors undertaking property work Thursday 22 December 2005 Introduction 1.Solicitors conducting conveyancing are at risk of money laundering because property transactions
More informationTHE UK S ANTI-MONEY LAUNDERING LEGISLATION AND THE DATA PROTECTION ACT 1998 GUIDANCE NOTES FOR THE FINANCIAL SECTOR. April 2002
THE UK S ANTI-MONEY LAUNDERING LEGISLATION AND THE DATA PROTECTION ACT 1998 GUIDANCE NOTES FOR THE FINANCIAL SECTOR April 2002 Introduction 1. This guidance has been prepared by the Government departments
More informationReport on Anti-Money Laundering/Countering the Financing of Terrorism and Financial Sanctions Compliance in the Life Insurance Sector in Ireland
2016 Report on Anti-Money Laundering/Countering the Financing of Terrorism and Financial Sanctions Compliance in the Life Insurance Sector in Ireland Compliance in the Life Insurance Sector in Ireland
More informationPetfre (Gibraltar) Ltd t/a Betfred.com Settlement following a licence review - public statement June 2016
Petfre (Gibraltar) Ltd t/a Betfred.com Settlement following a licence review - public statement June 2016 The issues identified in this statement are likely to form the basis for future compliance assessments
More informationAccess to Information by Succeeding Auditors
AA Access to Information by Succeeding Auditors September 2011 The Institute of Certified Public Accountants in Ireland Disclaimer This document has been developed by the Consultative Committee of Accountancy
More information(Unofficial translation by the Financial and Capital Market Commission)
(Unofficial translation by the Financial and Capital Market Commission) Text consolidated with amending laws of 12 December 2008; 01 December 2009; 10 December 2009. If a whole or part of a section has
More informationSUBSIDIARY LEGISLATION 373.01 PREVENTION OF MONEY LAUNDERING AND FUNDING OF TERRORISM REGULATIONS
AND FUNDING OF TERRORISM [S.L.373.01 1 SUBSIDIARY LEGISLATION 373.01 PREVENTION OF MONEY LAUNDERING AND FUNDING OF TERRORISM REGULATIONS 31st July, 2008 LEGAL NOTICE 180 of 2008, as amended by Legal Notices
More informationAnti-Money Laundering Policy 2014
Anti-Money Laundering Policy 2014 FOR INTERNAL USE ONLY Policy owner: AGM Compliance. Approving Authority Board of Directors Board of Directors Board of Directors Sign Off/ Approval date Earlier policy
More informationLaw Society of England and Wales - Chapter 3 - Money Laundering Regulations 2003
Law Society of England and Wales - Chapter 3 - Money Laundering Regulations 2003 Cut down version copied (on 5 November 2006) from: http://www.lawsociety.org.uk/professional/conduct/guideonline/view=page.law?policyid=225045
More informationNumber 6 of 2010 CRIMINAL JUSTICE (MONEY LAUNDERING AND TERRORIST FINANCING) ACT 2010 ARRANGEMENT OF SECTIONS. PART 1 Preliminary
Number 6 of 2010 CRIMINAL JUSTICE (MONEY LAUNDERING AND TERRORIST FINANCING) ACT 2010 ARRANGEMENT OF SECTIONS PART 1 Preliminary Section 1. Short title and commencement. 2. Interpretation. 3. Regulations.
More informationGuidance Notes for Life Assurance Companies
Return of Payments (Insurance Undertakings) Regulations 2011 (S.I. No. 641 of 2011) Guidance Notes for Life Assurance Companies These notes are intended to provide guidance for assurance companies on how
More informationANTI-MONEY LAUNDERING GUIDANCE FOR MEMBERS OF THE BODIES AFFILIATED TO THE CONSULTATIVE COMMITTEE OF ACCOUNTANCY BODIES IN IRELAND (CCAB-I)
ANTI-MONEY LAUNDERING GUIDANCE FOR MEMBERS OF THE BODIES AFFILIATED TO THE CONSULTATIVE COMMITTEE OF ACCOUNTANCY BODIES IN IRELAND (CCAB-I) Guidance for those providing audit, accountancy, tax advisory,
More informationESTONIA MONEY LAUNDERING AND TERRORISM FINANCING PREVENTION ACT
ESTONIA MONEY LAUNDERING AND TERRORISM FINANCING PREVENTION ACT Important Disclaimer This translation has been generously provided by the Estonian Financial Supervision Authority. This does not constitute
More informationMPS GROUP GLOBAL ANTI-MONEY LAUNDERING POLICY
Siena, march 2012 Pag. 1 di 5 MPS GROUP 1 - A p p l i c a t i o n This Global Anti-Money Laundering Policy (Policy) applies to all Banca Monte dei Paschi di Siena subsidiaries and branches (collectively
More informationCayman Islands Compliance Officer and the Role of the Money Laundering Reporting Officer
Cayman Islands Compliance Officer and the Role of the Money Laundering Reporting Officer Introduction Money laundering is the process by which the direct or indirect benefit of crime is channelled through
More informationCriminal Justice (Money Laundering and Terrorist Financing) Act 2010
Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 Guidelines On the prevention of the use of the financial system for the purpose of money laundering and terrorist financing February
More informationINSURANCE COMPANIES CONTROL SERVICE
REPUBLIC OF CYPRUS Orders for Life-Insurance Companies and Life-Insurance Intermediaries in accordance with Article 59(4) of the PREVENTION AND SUPPRESSION OF MONEY LAUNDERING ACTIVITIES LAW OF 2007 (THIRD
More informationPractice Note. 12(Revised) September 2010 MONEY LAUNDERING GUIDANCE FOR AUDITORS ON UK LEGISLATION
September 2010 Practice Note 12(Revised) MONEY LAUNDERING GUIDANCE FOR AUDITORS ON UK LEGISLATION The Auditing Practices Board (APB), which is part of the Financial Reporting Council (FRC), prepares for
More informationHELM TRUST COMPANY LIMITED COMPANY MANAGEMENT APPLICATION FORM
HELM TRUST COMPANY LIMITED COMPANY MANAGEMENT APPLICATION FORM PLEASE NOTE THAT IN ACCORDANCE WITH ANTI MONEY LAUNDERING LAWS NEW BUSINESS CANNOT BE ACCEPTED BY ANY JERSEY TRUST AND COMPANY BUSINESS SERVICE
More informationACT. [Long title substituted by s. 27 (1) of Act 33 of 2004.]
FINANCIAL INTELLIGENCE CENTRE ACT 38 OF 2001 [ASSENTED TO 28 NOVEMBER 2001] [DATE OF COMMENCEMENT: 1 FEBRUARY 2002] (Unless otherwise indicated) (English text signed by the President) as amended by Protection
More informationNon Financial Anti Money Laundering/Anti Terrorist Financing (AML/CFT) Regulations
Non Financial Anti Money Laundering/Anti Terrorist Financing (AML/CFT) Regulations Contents The contents of this module are divided into the following chapters, sections and schedules: CITATION... 1 ARTICLE
More informationACCOUNTANTS AND TAX ADVISORS
ACCOUNTANTS AND TAX ADVISORS Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not
More informationPaddy Power Holdings Ltd
Paddy Power Holdings Ltd Failures in anti-money laundering and social responsibility controls Public statement February 2016 The issues identified in this statement are likely to form the basis for future
More informationSole Trader Business & Agri
Sole Trader Business & Agri Business Current and Demand Deposit Account Application Pack CSS080533 - Sole Trader Application Pack 4-789S R13.indd 1 09/06/2014 11:42 5 Steps to opening your Business Account
More informationPREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM ACT
Law no. 10/2014 PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM ACT (unofficial English translation) PREVENTION OF MONEY LAUNDERING AND FINANCING OF TERRORISM ACT CONTENTS PART ONE PRELIMINARY
More informationDuties and responsibilities under the Proceeds of Crime Act 2002 Advice to operators (excluding casino operators) Second edition
Duties and responsibilities under the Proceeds of Crime Act 2002 Advice to operators (excluding casino operators) Second edition September 2014 Contents Part 1 - Introduction and summary of the advice
More informationAnti-Money Laundering Measures in the Cayman Islands
Anti-Money Laundering Measures in the Cayman Islands Foreword This memorandum has been prepared for the assistance of those who are considering the law of the Cayman Islands (sometimes referred to as Cayman
More informationOverview of Irish Law on Money Laundering
Overview of Irish Law on Money Laundering The material provided below is for information purposes only and does not constitute a legal document nor does it act as an interpretation of the law The main
More informationSwitching your personal current account made easy
Switching your personal current account made easy Introduction Summary of the Key Features of the Account Switching Code Bank of Ireland ( New Bank ) can facilitate all of the steps required in order to
More informationBANKING. Sector Specific AML/CFT Guidance Notes. May 2015
BANKING Sector Specific AML/CFT Guidance Notes May 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not be relied upon in respect
More informationSummary and Extracts from Law Society Guidelines on: Money Laundering Guide 2007 Mortgage Fraud Practice Note March 2008
Summary and Extracts from Law Society Guidelines on: Money Laundering Guide 2007 Mortgage Fraud Practice Note March 2008 What is Money Laundering? Money Laundering Regulations 2007 Summary of Law Society
More informationThe Wolfsberg Group Anti-Money Laundering Questionnaire. Financial Institution Name. 8 Canada Square, London E14 5HQ
The Wolfsberg Group Anti-Money Laundering Questionnaire Financial Institution Name Location HSBC Group 8 Canada Square, London E14 5HQ This questionnaire acts as an aid to firms conducting due diligence
More informationGuidance Notes to Applicant for Opening Corporate Investor Account in CCASS
香 港 中 央 結 算 有 限 公 司 ( 香 港 交 易 及 結 算 所 有 限 公 司 全 資 附 屬 公 司 ) Hong Kong Securities Clearing Company Limited (A wholly-owned subsidiary of Hong Kong Exchanges and Clearing Limited) Guidance Notes to Applicant
More informationInsurance Regulatory Authority GUIDELINES TO THE INSURANCE INDUSTRY ON IMPLEMENTATION OF THE PROCEEDS OF CRIME AND ANTI-MONEY LAUNDERING ACT
Insurance Regulatory Authority GUIDELINES TO THE INSURANCE INDUSTRY ON IMPLEMENTATION OF THE PROCEEDS OF CRIME AND ANTI-MONEY LAUNDERING ACT JUNE 2011 THE INSURANCE ACT (CAP 487) Guidelines To The Insurance
More informationCRIMINAL JUSTICE (TERRORIST OFFENCES) ACT 2005 GUIDANCE ON THE OFFENCE OF FINANCING OF TERRORISM AND THE FINANCIAL SANCTIONS REGIME
CRIMINAL JUSTICE (TERRORIST OFFENCES) ACT 2005 GUIDANCE ON THE OFFENCE OF FINANCING OF TERRORISM AND THE FINANCIAL SANCTIONS REGIME FOR BODIES DESIGNATED UNDER SECTION 32 OF THE CRIMINAL JUSTICE ACT, 1994
More informationΤHE CYPRUS BAR ASSOCIATION MONEY LAUNDERING: GUIDANCE NOTES FOR LAWYERS
ΤHE CYPRUS BAR ASSOCIATION MONEY LAUNDERING: GUIDANCE NOTES FOR LAWYERS These Guidance Notes are issued by the Council of the Bar Association of Cyprus appointed by the Council of Ministers on 7 March
More informationlow levels of compliance with the regulations and POCA by negligent HVD operators are enabling criminals to launder the proceeds of crime
6.185 Under the regulations HMRC must maintain a registry of HVDs. However the regulations do not enable HMRC to conduct a fit and proper person test on those who seek to register as an HVD. From 2004
More informationCORNWALL COUNCIL GUIDANCE NOTE ANTI-MONEY LAUNDERING POLICY
CORNWALL COUNCIL GUIDANCE NOTE ANTI-MONEY LAUNDERING POLICY 1.0 INTRODUCTION 1.1 Historically, legislation seeking to prevent the laundering of the proceeds of criminal activity was aimed at professionals
More informationGuidance Notes Applying for registration online
Guidance Notes Applying for registration online An Chomhairle um Ghairmithe Sláinte agus Cúraim Shóisialaigh Health and Social Care Professionals Council Important Please read these guidance notes before
More informationCODE ON THE PREVENTION MONEY LAUNDERING TERRORIST FINANCING
CODE ON THE PREVENTION of MONEY LAUNDERING & TERRORIST FINANCING (Issued under Section 7(1)(a) of the Financial Services Act 2007 and Section 18(1)(a) of the Financial Intelligence and Anti-Money Laundering
More informationGeneral overview of changes. Legislative changes. Andrew Le Brun Hamish Armstrong Financial crime policy. Overview (1)
General overview of changes Andrew Le Brun Hamish Armstrong Financial crime policy 1 Legislative changes 2 Overview (1) Legislative changes Money Laundering (Amendment No. 6) (Jersey) Order 2013 ( MLO
More informationAnti-Money Laundering Policy Manual Table of Contents [Sample Client] Table of Contents
Table of Contents [ Client] Table of Contents TABLE OF CONTENTS... 1 CHAPTER 1 INTRODUCTION... 3 1.1 GOALS AND OBJECTIVES... 3 1.2 REQUIRED REVIEW... 3 1.3 APPLICABILITY... 3 1.4 MONEY LAUNDERING DEFINED...
More informationI BASIC PROVISIONS. Subject matter Article 1
LAW ON THE PREVENTION OF MONEY LAUNDERING AND THE FINANCING OF TERRORISM ( Official Gazette of the Republic of Serbia, Nos 20/2009, 72/2009, 91/2010 and 139/2014) I BASIC PROVISIONS Subject matter Article
More informationTransit Visa Application
OFFICE USE ONLY Client no.: Date received: / / Application no.: November 2014 INZ 1019 Transit Visa Application Who can you include in your application? You can use this form to apply for a visa for a
More informationApplication for Status as a Registered Bank:
Application for Status as a Registered Bank: Material to be provided to the Reserve Bank Prudential Supervision Department Document Issued: Introduction 2 1. This release identifies the information which
More informationClient Update Fourth Anti-Money Laundering Directive Comes Into Force
1 Client Update Fourth Anti-Money Laundering Directive Comes Into Force OVERVIEW LONDON Karolos Seeger kseeger@debevoise.com Matthew Howard Getz mgetz@debevoise.com Alex Parker aparker@debevoise.com Ceri
More informationANTI-MONEY LAUNDERING GUIDANCE FOR INSOLVENCY PRACTITIONERS IN THE REPUBLIC OF IRELAND
ANTI-MONEY LAUNDERING GUIDANCE FOR INSOLVENCY PRACTITIONERS IN THE REPUBLIC OF IRELAND This guidance, which is specific to money laundering issues likely to arise in the context of insolvency practice,
More informationCode of Practice on Data Protection for the Insurance Sector
Code of Practice on Data Protection for the Insurance Sector (Approved by the Data Protection Commissioner under Section 13 (2) of the Data Protection Acts, 1988 and 2003) Forward I am very happy to be
More informationCONDUCTOR SAVINGS & INVESTMENT PLAN APPLICATION FORM
CONDUCTOR SAVINGS & INVESTMENT PLAN APPLICATION FORM AGENCY USE: Agency No. Agency Name OFFICE USE: Savings Plan ZSR Contract No. Client No. Investment Plan ZSS Please complete this application in BLOCK
More informationFinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now
FinCEN s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers: How to Prepare Now I. INTRODUCTION On August 25, 2015, the Financial Crimes Enforcement Network ( FinCEN ) proposed
More informationMoney Laundering Policy
(erouxs)u~~oc1u CiI1L06II Emirates Insurance Co. (~sc) Anti Money Laundering Policy Emirates Insurance Company PSC: Money Laundering Policy fr~iu~oliij UIiLc,UI a~pb Emirates Insurance Co. (rsci 1) Introduction
More informationBest Practices: Anti-Money Laundering and Customer Information Selected Requirements
Best Practices: Anti-Money Laundering and Customer Information Selected Requirements INTRODUCTION This document is intended to provide IIUSA members with guidance regarding anti-money laundering (AML),
More informationFINANCIAL SERVICES FLASH REPORT
FINANCIAL SERVICES FLASH REPORT The Fourth European Union Anti-Money Laundering Directive July 2015 The Fourth European Union (EU) Anti-Money Laundering Directive (Fourth Directive) was approved by the
More informationCustomer Due Diligence/ Know Your Customer (CDD/ KYC) Policy
Customer Due Diligence/ Know Your Customer 1. Introduction 1.1 JS Investments Limited (JSIL) has formulated a Customer Due Diligence/ Know Your Customer policy, referred here as CDD/ KYC policy, based
More informationAn Introduction to the UK Anti-Money Laundering Regime. slaughter and may. March 2008
An Introduction to the UK Anti-Money Laundering Regime slaughter and may March 2008 contents 1. Introduction 1 1.1 Money Laundering 1 1.2 The Regulated Sector 1 2. UK Anti-Money Laundering Measures 3 2.1
More informationBERMUDA PROCEEDS OF CRIME (ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING) REGULATIONS 2008 BR 77 / 2008
QUO FA T A F U E R N T BERMUDA PROCEEDS OF CRIME (ANTI-MONEY LAUNDERING AND ANTI-TERRORIST BR 77 / 2008 TABLE OF CONTENTS 1 2 3 4 5 6 7 8 8A 8B 8C 9 10 11 12 13 14 14A Citation and commencement Interpretation
More informationPREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM - BANKS
MAS Notice 626 24 April 2015 Last revised on 30 November 2015 (Refer to endnotes for history of amendments) NOTICE TO BANKS MONETARY AUTHORITY OF SINGAPORE ACT, CAP. 186 PREVENTION OF MONEY LAUNDERING
More informationPolicy on Prevention of Money Laundering and Terrorist Financing ABH Holding S.A.
Policy on Prevention of Money Laundering and Terrorist Financing ABH Holding S.A. 2013 CONTENT 1. GENERAL PROVISIONS... 3 2. THE SCOPE AND APPLICABILITY... 3 3. THE PURPOSE OF THE POLICY... 3 4. OBJECTIVES...
More informationMONEY LAUNDERING GUIDANCE FOR MEMBERS OF
MONEY LAUNDERING GUIDANCE FOR MEMBERS OF National Federation of Property Professionals Royal Institution of Chartered Surveyors Association of Relocation Professionals Association of Residential Managing
More informationUNDERSTANDING MONEY LAUNDERING
UNDERSTANDING MONEY LAUNDERING Preface In light of the international concerns growing on money laundering and the financing of terrorist activities, many countries have taken rigorous measures to curb
More informationANTI-MONEY LAUNDERING HANDBOOK & CODE OF PRACTICE FOR LAWYERS
FIRST DRAFT THE COMPLIANCE COMMISSION OF THE BAHAMAS ANTI-MONEY LAUNDERING HANDBOOK & CODE OF PRACTICE FOR LAWYERS Cecil Wallace-Whitfield Centre Cable Beach, West Bay Street P.O.Box N-3017 Nassau, BAHAMAS
More informationA guide to basic bank accounts
A guide to basic bank accounts Information about basic bank accounts It is our policy to pay Housing Benefit directly into a bank account. This type of payment is called a BACS payment. In order for us
More informationAnti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines
Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Guidelines for Banks, Financial Institutions, Credit Unions and Money Transfer Services Providers TABLE OF CONTENTS INTRODUCTION...
More informationING DIRECT Customer Identification Procedures for Brokers
ING DIRECT Customer Identification Procedures for Brokers Managing obligations of the Anti-Money Laundering and Counter-Terrorism Financing Act ( AML/CTF Act ) for the purpose of Customer Identification
More informationGuideline 6A: Record Keeping and Client Identification for Life Insurance Companies, Brokers and Agents
Guideline 6A: Record Keeping and Client Identification for Life Insurance Companies, Brokers and Agents Rev. 2014-02 Guideline 6A: Record Keeping and Client Identification for Life Insurance Companies,
More informationAML/CFT GUIDANCE FOR ATTORNEYS-AT-LAW
AML/CFT GUIDANCE FOR ATTORNEYS-AT-LAW PURPOSE AND CONTENTS The Financial Intelligence Unit of Trinidad and Tobago ( the FIU ) provides the following overview of the obligations under the Anti-Money Laundering/Counter
More informationAnti-Money Laundering and International Sanctions guidance for Coverholders
Anti-Money Laundering and International Sanctions guidance for Coverholders Introduction The purpose of this document is to provide general high-level guidance in relation to antimoney laundering ( AML
More informationInvestment Funds ISA Transfer Application
Investment Funds ISA Transfer Application How we will use your information Before continuing with this application, please read the information below which explains how we and others will use your personal
More information