Indicators for Investment Companies to Assist in Identifying Suspicious Transactions
|
|
- Britton Hines
- 7 years ago
- Views:
Transcription
1 Indicators for Investment Companies to Assist in Identifying Suspicious Transactions A suspicious transaction may involve several factors that may on their own seem insignificant, but when analyzed may raise suspicion that it involves proceeds of crime or funds related or linked to or to be used for money laundering or terrorism financing. A suspicious transaction report should be filed when a transaction or a group of transactions raise questions or apprehension or give rise to discomfort or lack of understanding of the transaction purpose or the nature of account transactions. The context in which a transaction occurs is a significant factor in assessing suspicion. This will vary from business to business and from one client to another. The investment firm and its employees should evaluate transactions in terms of what seems appropriate and is within normal practices in its particular line of business, and based on its knowledge of the client. The fact that transactions do not appear to be in keeping with normal industry practices may be a relevant factor for determining whether there are reasonable grounds to suspect that the transactions are related to money laundering or terrorist activity financing. Blanket explanations provided by the client (contracting party or beneficial owner) regarding the background of transactions in need of clarification are not sufficient as not every explanation provided by the client can be accepted at face value. Investment firms must verify the plausibility of every explanation provided to the extent possible. If the transaction is understandable and is not a source of discomfort, this should be documented accordingly. If the clarifications indicate that the transactions or fact patterns are suspicious, the reporting obligation pursuant to article 12 of the AML/CFT law is triggered. In all cases, an assessment of suspicion should be based on a reasonable evaluation of relevant 1
2 factors, including the knowledge of the customer s business, financial history, background and behavior. Also, it could be the consideration of many factors not just one factor that will lead to a conclusion that there are reasonable grounds to suspect that a transaction may be connected to money laundering or terrorism financing. All circumstances surrounding a transaction should be reviewed. The following indicators may be helpful in determining whether or not a transaction is suspicious. By themselves, the individual criteria may not trigger a suspicion and trigger the reporting obligation under Article 12 of the AML/CFT Law. But the coincidence of several criteria and/or the lack of plausible explanations may indicate a suspicion and thus trigger the reporting obligation. The following list of indicators is not exhaustive: General indicators 1. Lack of understanding of the client's reason for selecting this particular firm or branch to carry out the transactions. 2. Transactions or financial structures that lack economic reasons. 3. Transaction that seem to be inconsistent with the client s apparent financial standing or usual pattern of activities. 4. Transaction that appear to be out of the ordinary course for industry practice or do not appear to be economically viable for the client. 5. Transactions are unnecessarily complex for their stated purpose. 6. Obvious attempt by the client to evade or refuse attempts by the firm to establish personal contact. 7. Client does not want correspondence sent to home address. 8. Business relationships with legal entities not entered in publicly maintained registers or databases and from which no official certifications can be obtained. 2
3 9. When personal discussions are held, the client is always accompanied by other persons whose function is not apparent and who play a role in the design of the business relationship. 10. The client requests discretion that goes beyond the customary scope. 11. Indications of judicially punishable acts by the client in Kuwait or abroad. 12. Client admits or mentions involvement or is known to be involved in criminal activities. 13. The client shows uncommon curiosity about internal systems, controls, internal policies and monitoring. 14. The client over justifies or explains the transaction or exaggerates in providing documents to prove its authenticity. 15. The client is nervous, not in keeping with the nature of the transaction. 16. The client attempts to develop close rapport with staff. 17. The client uses aliases and a variety of similar but different addresses. 18. The client offers money, gratuities or unusual favors for the provision of services that may appear unusual or suspicious. 19. The client has no employment history but makes frequent large transactions or maintains a high account activity. Specific indicators A. Customer Due Diligence Measures 1. The client provides doubtful, vague or misleading identification information. 2. The client produces seemingly false identification or identification that appears to be counterfeited, altered or inaccurate. 3. The client refuses or is reluctant to produce personal identification documents. 4. The client only submits copies of personal identification documents. 5. The client wants to establish his identity using something other than his or her personal identification documents. 3
4 6. The client s supporting documentation lacks important details such as a phone number. 7. The client inordinately delays presenting corporate documents. 8. All identification presented is in foreign language or cannot be verified for some reason. 9. All identification documents presented appear new or have recently been issued. 10. Lack of cooperation by the client in identifying and verifying the identity of the beneficial owner in accordance with Article 5 of the AML/CFT Law. 11. Unexpected or frequent change of the beneficial owner. 12. Unexpected or frequent change of client contact details. 13. The client repeatedly uses an address but frequently changes the names involved. 14. The client provides contact data that does not match the contact data (address, telephone number) of the client's permanent residence. D. Accounts and Transactions 1. Opening accounts with names very close to those of other established business entities. 2. Attempting to open or operate accounts under a false name. 3. Actual activity obviously and rapidly exceeds activity projected at the time of opening of the account. 4. The structure of the client's business relationship with the firm lacks an economic rationale. 5. Early repayment of a loan or installments before they are due. 6. Client and other parties to a transaction have no apparent ties to the country where your firm is located. 7. Transactions involving a country with crime rates known to be high (e.g. widespread corruption, terrorism, and major drug production) or that are considered to be high risk countries from a money laundering and terrorism financing standpoint. 4
5 8. Accumulation of large balances that is inconsistent with the known turnover of the client s business. 9. Loans secured by obligations from offshore firms with difficulty to verify the validity of such obligations. E. Indicators of terrorist financing 1. Persons, companies, or organizations involved in the transaction are affected by targeted financial sanctions pursuant to Article 25 of the AML/CFT Law. 2. Transactions involving unregistered humanitarian organizations. 3. Frequent change of persons authorized to manage a certain account (authorized persons, beneficiaries, beneficial owners, etc.). 4. Frequent change of address, telephone number, account holders or authorized persons. 5. Information or indications of connections to known fundamentalist persons, organizations, or institutions. 6. Information or indications of support for fundamentalist publications or actions. 5
Indicators for Banks to Assist in Identifying Suspicious Transactions
Indicators for Banks to Assist in Identifying Suspicious Transactions A suspicious transaction may involve several factors that may on their own seem insignificant, but when analyzed may raise suspicion
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 information澳 門 金 融 管 理 局 AUTORIDADE MONETÁRIA DE MACAU EXAMPLES OF SUSPICIOUS TRANSACTIONS
EXAMPLES OF SUSPICIOUS TRANSACTIONS 1. Cash Transactions a) Transactions where large deposits and withdrawals above the minimum thresholds defined in the AML/CFT Guideline on Large Cash Transactions (including
More informationLIST OF INDICATORS FOR IDENTIFYING SUSPICIOUS TRANSACTIONS FOR ATTORNEYS AND LAW FIRMS
Republic of Serbia МINISTRY OF FINANCE Administration for the Prevention of Money Laundering LIST OF INDICATORS FOR IDENTIFYING SUSPICIOUS TRANSACTIONS RELATED TO TERRORISM FINANCING 1. A person refuses
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 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 informationMONEY LAUNDERING INDICATORS. 1. Financial professionals must pay especially close attention to the following indicators
Belgian Financial Intelligence Processing Unit Gulden Vlieslaan 55/ 1 1060 Brussels - Belgium Tel. : +32 2 533 72 11 Fax : +32 2 533 72 00 E-mail : info@ctif-cfi.be MONEY LAUNDERING INDICATORS NL1175F-EN
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 informationFIUs AND TERRORIST FINANCING ANALYSIS - A review by the Egmont Group of sanitised cases related to Terrorist Financing
FIUs AND TERRORIST FINANCING ANALYSIS - A review by the Egmont Group of sanitised cases related to Terrorist Financing Overview This document contains indicators of suspicious transactions that might be
More informationGUIDELINES TO MAS NOTICE 626 ON PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM
GUIDELINES TO MAS NOTICE 626 ON PREVENTION OF MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM Introduction 1. These Guidelines are issued to provide guidance to the banks on some of the requirements
More informationRev. 2010-12. Guideline 2: Suspicious Transactions
Rev. 2010-12 Guideline 2: Suspicious Transactions Guideline 2: Suspicious Transactions December 2010 This replaces the previous version of Guideline 2: Suspicious Transactions issued in December 2008.
More informationUnofficial translation of AML/ CFT Regulations for Banks
Unofficial translation of AML/ CFT Regulations for Banks Introduction The Central Bank of Egypt (CBE) issued on 19 November 2003 AML Regulations for Banks, according to the Anti money Laundering Law No.
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 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 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 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 informationPAYROLL AGENTS. Sector Specific AML/CFT Guidance Notes. August 2015
PAYROLL AGENTS Sector Specific AML/CFT Guidance Notes August 2015 Whilst this publication has been prepared by the Financial Supervision Commission, it is not a legal document and should not be relied
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 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 informationBANK INDONESIA REGULATION NUMBER: 5/ 21 /PBI/2003 CONCERNING
BANK INDONESIA REGULATION NUMBER: 5/ 21 /PBI/2003 CONCERNING SECOND AMENDMENT TO BANK INDONESIA REGULATION NUMBER 3/10/PBI/2001 CONCERNING APPLICATION OF KNOW YOUR CUSTOMER PRINCIPLES THE GOVERNOR OF BANK
More informationHIGH-RISK COUNTRIES IN AML MONITORING
HIGH-RISK COUNTRIES IN AML MONITORING ALICIA CORTEZ TABLE OF CONTENTS I. Introduction 3 II. High-Risk Countries 3 Customers 4 Products 7 Monitoring 8 Audit Considerations 8 III. Conclusion 10 IV. References
More informationD- To keep all the papers and documents justifying all transactions and operations for 10 years.
PROCEDURES MANUAL North Africa International Bank TITLE: Transfers, Cash Remittances and Withdrawals PROCEDURE NOTE Anti-Money Laundering (AML) and Anti-Terrorism Financing (ATF) Combating Procedures.
More informationSUSPICIOUS TRANSACTION GUIDELINE 2013
FINANCIAL INTELLIGENCE UNIT NEW ZEALAND POLICE SUSPICIOUS TRANSACTION GUIDELINE 2013 VERSION 1.0 TABLE OF CONTENTS 1 INTRODUCTION... 4 1.1 Background... 4 1.2 Purpose... 4 1.3 Scope... 4 1.4 FIU guidance
More informationRESPONSE TO FEEDBACK RECEIVED CONSULTATION ON ANTI- MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (AML/CFT) NOTICES AND GUIDELINES
RESPONSE TO FEEDBACK RECEIVED CONSULTATION ON ANTI- MONEY LAUNDERING AND COUNTERING THE FINANCING OF TERRORISM (AML/CFT) NOTICES AND GUIDELINES Introduction 1 In August 2006, MAS released a consultation
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 informationGENERAL INSTRUCTIONS FOR OBLIGED ENTITIES REGARDING THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING
1 (8) Basic Public Services, Legal Rights and Permits 22.9.2015 Supervision of trades GENERAL INSTRUCTIONS FOR OBLIGED ENTITIES REGARDING THE PREVENTION OF MONEY LAUNDERING AND TERRORIST FINANCING Money
More informationIn accordance with Article 14(5) of the Rules of Procedure of the Board of Supervisors, 2 the Board of Supervisors has adopted this Opinion.
EBA-Op-2016-07 12 April 2016 Opinion of the European Banking Authority on the application of customer due diligence measures to customers who are asylum seekers from higher-risk third countries or territories
More informationBackground. FIN-2010-G001 Issued: March 5, 2010 Subject: Guidance on Obtaining and Retaining Beneficial Ownership Information
Joint Release Financial Crimes Enforcement Network Board of Governors of the Federal Reserve System Federal Deposit Insurance Corporation National Credit Union Administration Office of the Comptroller
More informationCASES FORWARDED WITH REGARD TO CORRUPTION
BELGIAN FINANCIAL INTELLIGENCE PROCESSING UNIT CTIF-CFI Avenue de la Toison d Or - Gulden Vlieslaan 55/1-1060 Brussels - BELGIUM Tel.: + 32 (0)2 533 72 11 Fax: + 32 (0)2 533 72 00 E-mail: info@ctif-cfi.be
More informationTHE FORTY RECOMMENDATIONS OF THE FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING
THE FORTY RECOMMENDATIONS OF THE FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING 1990 A. GENERAL FRAMEWORK OF THE RECOMMENDATIONS 1. Each country should, without further delay, take steps to fully implement
More informationAutoridade Bancária e de Pagamentos de Timor-Leste Banking and Payments Authority of Timor-Leste
Autoridade Bancária e de Pagamentos de Timor-Leste Banking and Payments Authority of Timor-Leste PUBLIC INSTRUCTION 02/2004 ON THE PREVENTION OF MONEY LAUNDERING, CUSTOMER IDENTIFICATION AND RECORD-KEEPING
More informationFINANCIAL INTELLIGENCE UNIT MINISTRY OF FINANCE AND THE ECONOMY
GOVERNMENT OF THE REPUBLIC OF TRINIDAD AND TOBAGO FINANCIAL INTELLIGENCE UNIT MINISTRY OF FINANCE AND THE ECONOMY GUIDANCE NOTE AML/CFT PROCEDURES FOR POLITICALLY EXPOSED PERSONS PURPOSE AND CONTENTS The
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 informationWolfsberg Anti-Money Laundering Principles for Correspondent Banking
Wolfsberg Anti-Money Laundering Principles for Correspondent Banking 1 Preamble The Wolfsberg Group of International Financial Institutions 1 has agreed that these Principles constitute global guidance
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 informationPOTENTIAL MONEY LAUNDERING WARNING SIGNS POTENTIAL ABUSIVE ACTS - CUSTOMER ACTIVITY WARNING SIGNS
POTENTIAL MONEY LAUNDERING WARNING SIGNS POTENTIAL ABUSIVE ACTS - CUSTOMER ACTIVITY WARNING SIGNS Activity Inconsistent with the Customer s Business A customer opens several accounts for the type of business
More informationPresented By Greg Baldwin
ANTI-MONEY LAUNDERING COMPLIANCE OFFICER TRAINING Presented By Greg Baldwin THE ANTI-MONEY LAUNDERING COMPLIANCE OFFICER We re going to cover: Basis for the requirement to have a Compliance Officer The
More informationAML & Mortgage Fraud Compliance Program v. 08.2013 ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM
ANTI-MONEY LAUNDERING & MORTGAGE FRAUD COMPLIANCE PROGRAM Version: 2.0 dated 08.2013 TABLE OF CONTENTS AML & Mortgage Fraud Compliance Program 1.0 PURPOSE AND SCOPE... 3 2.0 APPLICABLE REGULATIONS AND
More informationRecommendations on internal control measures for prevention of money laundering and terrorist financing.
The Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences Recommendations on internal control measures for prevention of money laundering and terrorist financing.
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 informationTEMPLATE FOR REFERENCE ONLY
TEMPLATE FOR REFERENCE ONLY According to the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance, Chapter 615, Laws of Hong Kong, it is the responsibility of each financial
More informationGUIDANCE. for. Sole Practitioner Accountants, Accounting Firms and Sole Practitioner Auditors, Auditing Firms
Approved by the Decision of the Chairman of the Central Bank of the Republic of Armenia, No 1/875A of August 6, 2010 GUIDANCE for Sole Practitioner Accountants, Accounting Firms and Sole Practitioner Auditors,
More informationTYPOLOGY 13 MONEY LAUNDERING THROUGH CASINOS APPROVED BY THE DECISION OF THE GOVERNOR OF THE CENTRAL BANK OF ARMENIA NO 1/41A FROM JANUARY 24, 2014
APPROVED BY THE DECISION OF THE GOVERNOR OF THE CENTRAL BANK OF ARMENIA NO 1/41A FROM JANUARY 24, 2014 ANNEX TYPOLOGY 13 MONEY LAUNDERING THROUGH CASINOS YEREVAN 2014 1 Contents Chapter 1: Scope of Application...
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 informationSu Ning: Online verification of citizens identity information in China
Su Ning: Online verification of citizens identity information in China Remarks by Mr Su Ning, Deputy Governor of the People s Bank of China, at the press conference on the inauguration of the Online Verification
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 informationSUPPLEMENT TO THE GUIDELINE ON PREVENTION OF MONEY LAUNDERING
SUPPLEMENT TO THE GUIDELINE ON PREVENTION OF MONEY LAUNDERING A Guideline issued by the Monetary Authority under section 7(3) of the Banking Ordinance Revised July 2010 CONTENTS Page Section 1 Introduction...
More informationGuidelines of the Ufficio Italiano dei Cambi for Reporting
8 Guidelines of the Ufficio Italiano dei Cambi for Reporting Suspicious Transactions (10/12/2003) Guidelines for Reporting Suspicious Transactions Given the growing importance of the business of funds
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 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 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 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 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 informationNATIONAL INSURANCE COMMISSION AND FINANCIAL INTELLIGENCE CENTRE
NATIONAL INSURANCE COMMISSION AND FINANCIAL INTELLIGENCE CENTRE ANTI-MONEY LAUNDERING/ COMBATING FINANCING OF TERRORISM (AML/CFT) GUIDELINES FOR INSURANCE COMPANIES AND INSURANCE INTERMEDIARIES IN GHANA
More informationHANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING
HANDBOOK FOR FINANCIAL SERVICES BUSINESSES ON COUNTERING FINANCIAL CRIME AND TERRORIST FINANCING 15 December 2007 (updated March and April 2013) (Chapters 10 and 14 updated in accordance with Instructions
More informationADVISORY GUIDELINES OF THE FINANCIAL INTELLIGENCE UNIT
ADVISORY GUIDELINES OF THE FINANCIAL INTELLIGENCE UNIT REGARDING THE CHARACTERISTICS OF TRANSACTIONS SUSPECTED OF TERRORIST FINANCING 21 January 2013 1. The present explanatory guidelines have been issued
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 information16- INSTRUCTIONS ISSUED BY CENTRAL BANK OF KUWAIT REGARDING MONEY LAUNDERING
16- INSTRUCTIONS ISSUED BY CENTRAL BANK OF KUWAIT REGARDING MONEY LAUNDERING A) Circular to local banks on taking internal actions for implementing the rules of Law No. 35 of the year 2002 and its explanatory
More informationTITLE 31- - Money and Finance: Treasury
TITLE 31- - Money and Finance: Treasury Subtitle B- - Regulations Relating to Money and Finance Chapter X- - Financial Crimes Enforcement Network, Department of the Treasury PART 1021- - RULES FOR CASINOS
More informationBANQUE DU LIBAN. Basic Circular No 83 Addressed to Banks and also to Financial Institutions
BANQUE DU LIBAN Basic Circular No 83 Addressed to Banks and also to Financial Institutions Attached is a copy of Basic Decision 1 No. 7818 of May 18, 2001, and the Regulations on the Control of Financial
More informationBANK SECRECY ACT REQUIREMENTS FOR RESIDENTIAL MORTGAGE LOAN ORIGINATIORS: AN OVERVIEW
BANK SECRECY ACT REQUIREMENTS FOR RESIDENTIAL MORTGAGE LOAN ORIGINATIORS: AN OVERVIEW June 6, 2012 Marjorie A. Corwin, Esquire Gordon Feinblatt LLC 233 East Redwood Street Baltimore, Maryland 21202 410-576-4041
More information(Unofficial translation by the Financial and Capital Market Commission)
1 (Unofficial translation by the Financial and Capital Market Commission) Law on Payment Services and Electronic Money (Title of the Law in the wording of the Law of 17 March 2011 that is in effect as
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 informationto The Uganda Gazette No. 67 Volume CIII dated 12th November, 2010 Printed by UPPC, Entebbe, by Order of the Government. 2010 No. 46.
STATUTORY INSTRUMENTS SUPPLEMENT No. 32 12th November, 2010 STATUTORY INSTRUMENTS SUPPLEMENT to The Uganda Gazette No. 67 Volume CIII dated 12th November, 2010 Printed by UPPC, Entebbe, by Order of the
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 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 informationMiddle East & North Africa Financial Action Task Force. Designated Non-Financial Businesses and Professions (DNFBPs) in relation to AML/CFT
Middle East & North Africa Financial Action Task Force Designated Non-Financial Businesses and Professions (DNFBPs) in relation to AML/CFT 10 November 2008 Document Language: English Original: Arabic 2008
More informationJersey MONEYVAL Report Summary
Jersey MONEYVAL Report Summary Introduction The MONEYVAL report issued today (Tuesday 24 May, 2016) comprehensively sets out the position of the Island against a number, but not all, of the Financial Action
More informationStrategic analysis brief Money laundering through real estate
Strategic analysis brief Money laundering through real estate Strategic analysis briefs AUSTRAC strategic analysis briefs provide insights for government and industry on money laundering and terrorism
More informationLaw No. 80 for 2002 Promulgating the Anti-Money Laundering Law And its Amendments ١
Law No. 80 for 2002 Promulgating the Anti-Money Laundering Law And its Amendments ١ In the Name of the People, The President of the Republic, The People's Assembly has passed the following Law, and we
More informationEthics Pronouncement EP 200
Ethics Pronouncement EP 200 Anti-Money Laundering and Countering the Financing of Terrorism Requirements and Guidelines for Professional Accountants in Singapore This Pronouncement was issued by the Council
More informationANTI-MONEY LANDERING & COUNTER TERRORISM FINANCING POLICY
ANTI-MONEY LANDERING & COUNTER TERRORISM FINANCING POLICY Company: Union Standard International Group Pty Ltd Company trading as: USGFX ACN: 117 658 349 AFSL: 302792 Date Updated: 11 th November 2014 1
More informationIdentification and Reporting of Suspicious Transactions in Banks. David Hsu Country Compliance Officer Citibank, N.A., Hong Kong
Identification and Reporting of Suspicious Transactions in Banks David Hsu Country Compliance Officer Citibank, N.A., Hong Kong AGENDA Identification of Suspicious Transactions Case Sharing Suspicious
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 informationAppendix 1. The text in this appendix is new and is not underlined and struck through in the usual manner. The DFSA Rulebook
Appendix 1 The text in this appendix is new and is not underlined and struck through in the usual manner. The DFSA Rulebook Representative Office Module (REP) Contents The contents of this module are divided
More informationREPUBLIC OF ARMENIA LAW ON COMBATING MONEY LAUNDERING AND TERRORISM FINANCING
REPUBLIC OF ARMENIA LAW ON COMBATING MONEY LAUNDERING AND TERRORISM FINANCING CHAPTER 1 GENERAL PROVISIONS The purpose of this Law shall be protecting the rights, freedoms, and legitimate interests of
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 informationCommittee of experts on the evaluation of anti-money laundering measures and the financing of terrorism MONEYVAL
MONEYVAL(2010) 9 18 March 2010 Committee of experts on the evaluation of anti-money laundering measures and the financing of terrorism MONEYVAL Typology research Money laundering through private pension
More informationAnti-Money Laundering Facts
Anti-Money Laundering Facts Security Benefit Life Insurance Company (SBL) has implemented a formal anti-money laundering (AML) program in response to the Financial Crimes Enforcement Network s (FinCEN)
More information16- COMBAT OF MONEY LAUNDERING AND TERROR FINANCING TRANSACTIONS
16- COMBAT OF MONEY LAUNDERING AND TERROR FINANCING TRANSACTIONS A) Instructions issued by Central Bank of Kuwait concerning money laundering and terror financing transactions. B) Circular concerning the
More informationWhat Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies
What Insurance Agents and Brokers Should Expect under the New Anti-Money Laundering Regulations for Life Insurance Companies The USA PATRIOT Act includes provisions intended to prevent the financial services
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 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 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 informationANTI-MONEY LAUNDERING/ COUNTER TERRORISM FINANCING POLICY
ANTI-MONEY LAUNDERING/ COUNTER TERRORISM FINANCING POLICY TABLE OF CONTENTS EXECUTIVE SUMMARY... 3 Preamble... 3 Policy Parameters... 4 KEY TERMS... 4 POLICY OBJECTIVE, RATIONALE AND DELIVERABLES... 6
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 informationWolfsberg Frequently Asked Questions ("FAQs") on Correspondent Banking
Preamble Wolfsberg Frequently Asked Questions ("FAQs") on Correspondent Banking The Principles constitute global guidance on the establishment and maintenance of Foreign Correspondent Banking relationships,
More informationGUIDELINES for the analysis and assessment of money laundering and terrorist financing risks for credit institutions and credit unions
Pursuant to Article 88 of the Anti Money Laundering and Terrorist Financing Law (Official Gazette 87/2008) and Article 43, paragraph 2, item 9 of the Act on the Croatian National Bank (Official Gazette
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 informationJoint Stock Bank of Gas Industry (Closed Joint Stock Company)
Joint Stock Bank of Gas Industry (Closed Joint Stock Company) APPROVED by Resolution of the Executive Committee of JSB Gazprombank (CJSC) dated the 7 th of February 2007 Minutes No.06 Policy of JSB Gazprombank
More informationPurpose of this document
Independent Financial Advisors (IFAs), Mortgage Brokers and Retail Intermediaries: Identifying Risks to your Business and Reporting Suspicious Activity This is a United Kingdom Financial Intelligence Unit
More informationStrategic analysis brief Money laundering through legal practitioners
Strategic analysis brief Money laundering through legal practitioners Strategic analysis briefs AUSTRAC strategic analysis briefs provide insights for government and industry on money laundering and terrorism
More informationBank Secrecy Act Anti-Money Laundering Examination Manual
Bank Secrecy Act Anti-Money Laundering Examination Manual Core Overview - Customer Identification Program Assess the bank's compliance with the statutory and regulatory requirements for the Customer Identification
More informationPlatform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy
1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,
More informationDORMANT BANK ACCOUNTS (JERSEY) LAW 201-
DORMANT BANK ACCOUNTS (JERSEY) LAW 201- REPORT Explanatory Note Draft 12A 7 July 2015 Page - 1 File No.711 Dormant Bank Accounts (Jersey) Law 201- Arrangement DORMANT BANK ACCOUNTS (JERSEY) LAW 201- Arrangement
More informationBasel Committee on Banking Supervision
Basel Committee on Banking Supervision Sound management of risks related to money laundering and financing of terrorism January 2014 This publication is available on the BIS website (www.bis.org). Bank
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 informationSELF-REGULATION RULES OF THE ASSOCIATION ROMANDE DES INTERMÉDIAIRES FINANCIERS (ARIF)
1 SELF-REGULATION RULES OF THE ASSOCIATION ROMANDE DES INTERMÉDIAIRES FINANCIERS (ARIF) A. GENERALITIES Purpose of the Rules 1 The Self-Regulation Rules, enacted by the Association romande des intermédiaires
More informationTRUST SERVICE PROVIDERS AND CORPORATE SERVICE PROVIDERS
TRUST SERVICE PROVIDERS AND CORPORATE SERVICE PROVIDERS Sector Specific AML/CFT Guidance Notes December 2015 Whilst this publication has been prepared by the Financial Services Authority, it is not a legal
More informationAccount Opening/Client Identification Program and Monitoring Client Activity
Account Opening/Client Identification Program and Monitoring Client Activity To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions
More information