Course Overview

Money laundering is a clear and present danger that globally continues to pose a significant threat to governments, financial institutions, and businesses alike. As a result, financial institutions, banks, and corporations across the globe are required to set in place a BSA/AML Compliance Program.

An Anti-Money Laundering Compliance Program for any corporation or financial institution states all the efforts and steps taken by them in order to keep in line with regulatory AML policies in their legislative and legal environment (state, national, and international AML laws). An AML Compliance Program is aimed at keeping in check illicit financial activities, such as: fraud, money laundering, and terrorist financing.

The governance and success of this program rests responsible upon the Compliance team. In the Anti Money Laundering world of compliance, these personnel are referred to as the second line of defence, the “behind-the-scenes-operators”, these folks develop policies and procedures, devise templates, reports, tuning mechanism, customer questionnaires and requirements, alongside the technologies necessary to streamline KYC and AML processes.

The compliance team is responsible for setting risk categories and monitor ongoing Suspicious Activities Reporting.  They are responsible for tracking any wilful or unwilful violations of oversight in following the set national regulations that poses a threat for financial institutions.  An AML Compliance Program supports businesses to keep track of transactions and flag off any illegal financial activities to the concerned authorities.

Institutions are charged with hefty penalties or fines for lack of compliance. This being a common issue globally for financial institutions as keeping up with AML compliance can be difficult, especially for uninformed and not-updated compliance teams.

A successful compliance team are the ones that are aware of the latest regulations and laws, both regional and international, which are subject to updates and changes frequently. To address this issue, there’s a known best practice also, considered a ‘Third Pillar’ of an AML compliance program, i.e. Staff Training. A well informed and appraised Compliance team stays informed and keeps track of changing regulations, as well as the changing nature of businesses, regional jurisdictions, their risk profiles, systems and processes.

The success of an AML/BSA compliance hinges on essential indicators such as strong internal processes, as well as strict risk assessment of clients based on their industry and type of business.

However, the most important factor to build an effective AML Compliance Program is in fundamental regulatory and legal understanding, executed by knowledgeable professionals who are qualified to create a system that ensures compliance at each organizational level.

This Zoe masterclass for Compliance professionals is aimed to cover all aspects from the basics to advance of Anti-Money Laundering compliance creation, governance, tuning, upgrading and efficacy.

Course Objectives

As the industry understanding prevails that AML compliance is imperative for financial institutions and corporates alike. The priority one item on the agenda is outlining definitive corporate policies for requisite compliances such as BSA/AML, in order to minimize the risks for the institution to be used for illicit financial activities by its customers.

For any organization aiming to create an enterprise-wide climate for compliance, or having a system that is robust for compliance adherence, is successful in keeping checks on illegal activities, such as money laundering and terrorist financing.

A well knowledgeable compliance director and their teams are aware of both legal and fiscal repercussions of being involved in or enabling such dealings for corporations and financial institutions. Non-compliance is often met with heavy fines and legal consequences.

After completing this course, the Compliance team and compliance representatives from each department will learn all facets of running a good AML Compliance Program that includes:

• Designing and running Internal operations and regulations governance
• Customer vetting, onboarding and processing policies
• Account Operations monitoring, general reviews and reconciliations
• Transaction monitoring, case detection, reporting protocol, SAR/STR/CTR filing
• Developing robust AML Compliance Standards
• Analysing legal obligations and potential risks
• Working knowledge of acquiring and adopting adequate technology
• Developing an industry/organization-specific training material
• Overview of Legal advisory for consulting and defence
• Understanding the independent audit process and the importance of conducting routine checks is an effective way, to understand the shortcomings of their risk assessment and compliance program

Training Methodology

This is an interactive training course and will consist of the following training approaches:

• Lectures
• Webinars/Seminars & Presentations
• Group Discussions
• Bod & Sr. Mgmt. Consulting sessions
• AML KYC Policy Documentation Analysis
• Compliance Team Focus Group Discussions

Organizational Benefits

• Reduce the risk of non-compliance
• Steer the institutions away from heavy fines, penalties and reputation damage, which, in turn, result in loss of customers and revenue
• Keep a check on the illicit use of the organization and linkage to criminal financial networks
• Monitor, detect and report suspicious activities that indicates possible money laundering
• In all ensure compliance that is effective, dynamic, scalable, and adaptable
• Designing and implementing an effective program, that refers to a set of policies and procedures that work for the organization’s unique AML requirements
• The resultant effect of this course is a strong foundation of internal values to guide employees at each and every level of the organization
• Learn organizational vulnerabilities from the point of view of risk factors like nature, diversity, complexity, scale, volume, and size of its business and operations
• Set Internal privacy and security guidelines
• Gain an understanding in streamlining Audit function of the organization with well-tuned systems

Personal Benefits

• Understanding the movement in a compliance environment and enhance your career by selecting to master one of the branches in this vast subject
• Career advancement into AML/BSA compliance
• Candidates with a proper hold on the subject matter can be considered for more responsible positions in the organization
• Compliance responsibility is usually carried out by the Compliance Officer, also seen as an advisor to the senior management and Board Members
• Understand the financial crime landscape and implement it in personal life and financial dealings to stay safe and legally secured
• As the Designated Director, Compliance Officer or the MLRO have personal liabilities in case of non-compliance; knowing the compliance in-depth is obviously of personal value
• Become an expert with knowledge of compliance regulations, knowledge of important regulatory databases, compliance analysis methods, and knowledge of internal risk audits

Who Should Attend?

This course offers complete knowledge in AML/KYC regulations, compliance, assessment and management.  The following individuals or groups will benefit from it:

• Designated Director / MLRO / Compliance Officer
• Compliance personnel
• Legal team / retained-external counsel
• Compliance representatives or appointed point of contact from each department
• Internal Auditors
• Financial advisors to the Board of Directors
• HNI operations HoD
• Human Resource dept. HoD
• Marketing dept. HoD
• Private Banking and relationship HoD’s

Course Outline

Module 1 – Setting an AML/CFT Compliance Program

• AML/CFT Program
• The Elements of an AML/CFT Program
• Structuring the Compliance Function
• A Programme of Internal Policies, Procedures and Controls
• Assessing AML/CFT Risk
  – AML/CFT Program
  – AML/CFT Training
  – Establishing a Culture of Compliance

Module 2 – Risk Assessment

• Assessing AML/CFT Risk
• Maintaining an AML/CFT Risk Model
• Understanding AML/CFT Risk
• AML/CFT Risk Scoring
• Assessing the Dynamic Risk of Customers
• AML/CFT Risk Identification
  – Customer Type
  – Geographic Location
  – Products/Services

Module 3 – The Designation and Responsibilities of a Compliance Officer

• Appointment of Designated Director
• Communication
• Delegation of AML Duties
• Compliance Officer Accountability

Module 4 – Staff Training

• AML/CFT Training
  – Components of an effective training program
  – Who to Train?
  – What to Train on?
  – How to Train?
  – When to Train?
  – Where to Train?

Module 5 – Vendor Services Procurement

• External Audit
• Training & Testing
• MLRO Support
• On-going consulting – New circular interpretations
• Technology (Procurement)
• Risk Assessment System – Transaction Monitoring System – Sanctions Screening System – Beneficial Ownership Tracker

Module 6 – Independent Audit

• Evaluating an AML/CFT Program
• All the governance parameters
• Compliance Officer’s Management
• Compliance Structure
• Compliance Staff and efficacy
• Compliance function efficacy, procedures and documentation
• Adherence to the Recommended AML/BSA program

Module 7 – Sanctions Screening

Economic Sanctions
UNITED NATIONS | EUROPEAN UNION | UNITED STATES

• Sanctions List Screening
• Politically Exposed Persons Screening
• Beneficial Ownership
• Know Your Employee

Module 8 – Sources of Investigations

• Regulatory recommendations or Official findings
• Transaction Monitoring
• Referrals from customer-facing employees
• Internal Hotlines
• Negative media information

Module 9 – Conducting the Investigation

• Utilizing the internet when
• Conducting financial investigations
• STR Decision-Making Process
• Filing an STR
• Quality Assurance
• STR filing oversight/escalation
• Closing the Account