Advanced AML and CFT Practitioner

AML CFT

Advanced Practitioner

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Compliance Frameworks The Frameworks

The string of Money Laundering cases showcased in the media throughout 2018 including Danske Bank, Deutsche Bank, Pilatus Bank, Commonwealth Bank of Australia, and ABLV Bank Latvia have cogently demonstrated the huge inadequacies in pre-existing Know Your Client (KYC), AntiMoney Laundering (AML) and Counter-the-Financing of Terrorism (CFT) compliance frameworks.

Moreover, reports in the United Kingdom (UK) have identified key areas of concern, such as law firms and trust and corporate service providers as being high risk for exposure to money laundering. In addition, reports by the Financial Conduct Authority (FCA) have identified areas of weakness.

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With ever more advanced money laundering techniques, technologies, and strategies being leveraged by criminal networks across the world, firms need to ensure that they have highly efficient KYC, AML and CFT compliance frameworks in place that are kept up-to-date with the latest KYC, AML and CFT trends and developments around the world.

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The Advanced AML/CFT Practitioner training course has been designed to provide one of the most comprehensive and advanced learning experiences covering AML and CFT frameworks available on the market today. It features some of the very best training materials covering legal, operational, technological, and strategic AML/CFT global perspectives.

It draws upon a broad array of legislative requirements, international Financial Action Task Force (FATF) guidance, national guidance materials from the United Kingdom (UK) Financial Conduct Authority and HM Treasury, as well as a broad range of practical and legal case studies that exemplify practical ML and TF techniques and strategies in use today. It covers inter alia global AML/CFT trends and challenges; the Nominated Officer role and responsibilities; the Fourth AntiMoney Laundering Directive framework; AML/CFT legal frameworks; ML typologies; concealment of beneficial ownership; AML/ CFT risk assessments; advanced ML/ TF risk assessment methodologies and monitoring; AML/CFT case studies; AML/ CFT operational compliance; and a review of AML/CFT technologies.

About the Training Course Training Course

These include deficiencies in AML controls, ineffective enhanced due diligence (EDD) combined with poor identification and monitoring of high-risk customers and Politically Exposed Persons (PEPs); and the design of processes and allocated responsibilities (e.g. customerfacing staff had limited training to help them assess money laundering risks).

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he Session

The Sessions 6

DAY 1

SESSION 1 AML and CFT Global Trends and Challenges • Global View of AML and CFT Cases and Fines, Developments in High Risk Third Countries, Developments in Higher Risk Third Countries; An Update on High End Money Laundering, Strategy and Action Plan.

• An Overview of the Financial Conduct Authority (FCA) AML Annual Report (2015-2016; 2016-2017).

• A Review of ‘FCA Financial Crime: A Guide for Firms’ and ‘Joint Money Laundering Steering Group Guidance’.

SESSION 2 A Review of the Nominated Officer Role and Responsibilities • The Role of the Nominated Officer (NO), NO Characteristics (Trust, Seniority, Independence), NO Responsibilities; Additional NO Responsibilities (AntiMoney Laundering (AML) Controls and Procedures, Record Keeping, Staff Training), and Countering the Financing of Terrorism (CFT) Controls and Procedures.

• Client Due Diligence (General, Enhanced, Simplified, Reliance and Record Keeping, Beneficial Ownership Information).

• Risk Assessment, Policies and Procedures, Employee Training, Money Laundering Investigation and Law Enforcement, Civil and Criminal Penalties.

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SESSION 3 The Fourth Anti-Money Laundering Directive and the European Supervisory Authorities Guidelines • The Fourth Anti-money Laundering Directive (4AMLD) (Mitigating Measures; Definitions; 4AMLD Obliged Entities; Exceptions; Commission Risk Assessment; Member State Risk Assessment; 4AMLD Obliged Entity Risk Assessment).

• Third Party Outsourcing (Third Parties; Third Party Outsourcing Conditions); High Risk Jurisdictions (Financial Action Task Force (FATF) High Risk Jurisdictions; European Union High Risk Third Country List).

• Beneficial Ownership Information (Beneficial Ownership Central Register; Beneficial Ownership Information Exemption); The European Supervisory Authorities Guidelines; Commission Assessment (40 Products or Services; 11 Professional Sectors; Findings).

SESSION 4 AML and CTF Legal Frameworks • An Overview of Part 7 of the Proceeds of Crime Act 2002 (Section 340 Definitions; Section 327 Concealing etc; Section 328 Arrangements; Section 329 Acquisition, Use, and Possession) and Part 3 of the Terrorism Act 2000 (Terrorist Property; Fund Raising; Use and Possession; Funding Arrangements).

• A Review of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (No. 692).

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• An Overview of Section 59 Financial Services and Markets Act 2000 (FSMA) and Controlled Function Status and the Criminal Finances Act 2017.

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DAY 2

SESSION 5

SESSION 7

A Review of Money Laundering Methods

AML and CFT Risk Assessments

• Assets (gold, jewellery, raw diamonds, antiquities, art); Real Estate (Legal Estate, Equitable Interests, Property Values, Cash Deposits); Deposit Boxes; Private Cash Deals; Currency Exchange Offices, Loans and Mortgages.

• The Growing Use of Third Party Intermediaries (TPIs) (Consulting Firms; Legal Professionals; Trust and Company Service Providers; Accountants) and New Areas (Capital Markets; Mergers and Acquisitions).

• TPI Vulnerabilities (Shelf Companies, Directorship, Trustee, Virtual Office, Mailbox Services, Trusts, Client Accounts, Client Advocacy and Brokerage Services), and Environmental Vulnerabilities (Jurisdictional Vulnerabilities, Vulnerable Business Practices).

• Conducting a Risk-Based Approach (Focus on Outputs, Focus AML Resources, Seeking out Information on Money-Laundering Trends, Threats from External Sources).

• Completing an AML/CFT Risk Assessment of the Business Utilising Risk Categories (Geographic Risk, Product Risk, Service Risk, Investor Risk, Channel Risk, Distribution Risk).

SESSION 8

SESSION 6

Advanced Risk Assessment Methodologies and Monitoring

Concealment of Beneficial Ownership

• Client Risk Rating (Jurisdiction, Political Status, Legal Persons and Arrangements, Industry Type); Country or Geographic Risks; Product Type Risks; Delivery Channel Risks; Risk Rating Methodologies; Risk Rating Scale.

• What is Beneficial Ownership; Beneficial Ownership Requirements around the World; Beneficial Ownership Registries.

• Misuse of Legal Persons and Arrangements (Capital Companies, Partnerships, Limited Liability Companies, Foundations, Trusts).

• Techniques used to Obscure Beneficial Ownership (Complex Ownership and Control Structures, Use of Individuals, Use of Financial Instruments, Falsifying Activities).

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• Firm Wide Risk Assessment, Risk Factors, Risk Assessment taking into account the Size and Nature of the Business, European Banking Authority Guidelines on Risk Based Supervision.

• Integration of Third Party Systems (Criminal Records, Black Lists, White Lists, PEPs, Corruption Indexes, Negative News Screening, Data Feeds (Application Programming Interfaces (APIs))).

• Transaction Filtering and Monitoring, Automated UK Analytics, Internal Audit (Audit Committee Participation, Subject Matter Knowledge, Escalations, New Business Committee).

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DAY 3

SESSION 9

SESSION 11

AML and CFT Case Studies - PART I

AML and CFT Operational Compliance

• Practical Case Studies (Disguising Source of Funds; Money Service Businesses; Black Market Peso Exchange; Hawala; ML with Derivatives; ML with Syndicated Loans).

• A Guide to Legal Professional Privilege (LPP) (Litigation Advice Privilege; Legal Advice Privilege; LPP Exception; Abuse of Privilege).

• Basic and Complex Trade-Based Finance Methods (Over-Invoicing, Under-Invoicing, and Multiple Invoicing of Goods and Services; Over-Shipments and Under-Shipments of Goods and Services; Falsely Described Goods and Services) and Case Studies (Black Market Peso Exchange Arrangements; United States; India; China; Singapore).

• Country Case Studies; Case Studies (Australia); Case Studies (Argentina); Case Studies (Belgium); Case Studies (Bolivia); Case Studies (Canada); Case Studies (Cayman Islands); Case Studies (China).

• Disclosure of Suspicious Activity Reports (SARs) to the National Crime Agency; A Review of SAR Reports; SAR Guidelines, Best Practices, and Case Studies.

• AML Checks; KYC Checks; Client Suitability Checks; ID Verification; Politically Exposed Persons (PEPs), Close Associates, and Family Members; Sanctions Screening; Narrative Sanctions; Ultimate Beneficial Ownership (UBO) Discovery Process; Adverse Media Searches; Government Records; State Owned Entities and State invested Enterprises; Global Sanctions Lists; HMRC Financial Sanctions List; Office of Foreign Assets Control (OFAC); Best Practices.

SESSION 12 SESSION 10 AML and CFT Case Studies - PART II • A Review of AML, CFT, and Virtual Currencies (Convertible v. Non-Convertible Virtual Currencies; Centralised v. Non-Centralised Virtual Currencies) and Case Studies (Liberty Reserve; Silk Road; Western Express International).

• A Review of Global Enforcement Cases relating to ML and TF (U.S. Bancorp; Rabobank; Commonwealth Bank of Australia; ING; UBS).

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• A Review of UK Enforcement Cases relating to ML and TF (Standard Bank PLC, Coutts, EFG, Turkish Bank (UK) Ltd, Guaranty Trust Bank (UK) Ltd, Habib Bank AG Zurich, Deutsche Bank).

AML and CFT Technologies • A Review of the Latest AML and CFT Compliance Technology Features (Artificial Intelligence (AI) RiskDriven Databases (Companies, People); AML Real Time Facial Recognition Identification).

• KYC, AML and CFT Case Study: ComplyAdvantage (Screening and Monitoring Technology; Data Feeds; Sanctions and Watchlist Screening; PEP Profiles; Adverse Media; Customer Onboarding and Monitoring; Payment Screening; Monitoring to Spot Suspicious Behaviour).

• KYC, AML and CFT Case Study: KYC Portal (Application UK Overview; Embedded Facial Recognition; Custom Risk Scoring; Embedded Face-To-Face Video Interviews; Granular Notifications; Real Time Transaction Monitoring; Customer Outreach Tool).

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• Attendees will benefit from extremely Comprehensive Training covering all the most relevant parts of AML and CFT frameworks.

• Attendees will be provided with highly interactive training drawing upon a highly diverse range of practical discussions and real life case studies.

• The training course will afford attendees an opportunity to become fully up-to-date with the latest and most relevant trends and developments in AML and CFT frameworks around the world.

• The training course will provide Money Laundering Reporting Officers and AML/ CFT professionals with materials to develop internal training courses for firm employees.

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The Key Benefits The Key Benefits

Key Benefits

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he Key Takeaway The Key Takeaways 16

Key Takeaways • Three (3) Highly Comprehensive Training Course Manuals, Training Course Reference Materials Manual, and Twelve (12) PowerPoint Presentations.

• Accrue Twelve (12) ACAMS Credits through ACAMS Certification.

• Advanced AML/CFT Practitioner Certification and Certificate.

• Embossed Storm-7 Consulting Continuing Professional Development (CPD) Certificate.

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