The document discusses money laundering, including defining it, describing the process, and providing case studies. Money laundering is defined as disguising illegally obtained money to make it appear legitimate. The process typically involves three stages: placement, layering, and integration. Placement involves putting dirty money into the financial system. Layering involves separating the money from its source through transactions. Integration makes the money appear clean. Case studies show how professionals like lawyers and accountants can be used to launder money through techniques like shell companies and structured transactions. Estimates suggest $600 billion to $2 trillion may be laundered annually, impacting economies and banking systems.
Basics of Anti-Money Laundering : A Really Quick Primer
What is Money Laundering?
The act of concealing or disguising (laundering) of funds obtained through illegal activity
so that they appear to have been generated through legal, legitimate sources.
How is it Carried Out?
Shell companies, intermediaries and money transmitters usually transfer these funds around the world Banks and other financial institutions are the chosen medium for laundering these illegal funds
AML Regulations:
The Bank Secrecy Act is the most important Anti-Money Laundering (AML) regulation
The BSA requires financial institutions to:
Keep records of cash purchases of negotiable instruments
File reports of cash transactions exceeding $10,000 (daily aggregate amount)
Report suspicious activity that might signify money laundering, tax evasion, or other criminal activities
Implement a written, board-approved compliance monitoring program
The USA Patriot Act
Expands AML requirements to all financial institutions
Augments existing BSA framework
AML Best Practices:
In order to combat money laundering, banks should implement the following best practices:
Customer Identification Program (CIP)
Customer Due Diligence (CDD) Program
Bank Secrecy Act/Anti-Money Laundering Risk Assessment
Identification and Reporting of Suspicious Activity
Want to learn more about anti-money laundering process and best practices? ComplianceOnline webinars and seminars are a great training resource. Check out the following links:
http://www.complianceonline.com/anti-money-laundering-aml-compliance-program-seminar-training-80114SEM-prdsm?channel=amlppt
http://www.complianceonline.com/bsa-aml-ofac-risk-assessments-regulatory-requirements-seminar-training-80181SEM-prdsm?channel=ppt
http://www.complianceonline.com/bsa-aml-compliance-reporting-requirements-webinar-training-703352-prdw?channel=amlppt
http://www.complianceonline.com/bsa-aml-compliance-checklists-webinar-training-703178-prdw?channel=amlppt
http://www.complianceonline.com/bsa-aml-ofac-risk-assessments-and-evaluation-compliance-program-webinar-training-703493-prdw?channel=amlppt
http://www.complianceonline.com/best-practices-for-developing-risk-models-for-aml-bsa-monitoring-webinar-training-703628-prdw?channel=amlppt
This presented is aimed at AML/CTF practitioners who would need quick reminders of the basics of AML. Tools are not very useful if the underlying basics are unknown.
Basics of Anti-Money Laundering : A Really Quick Primer
What is Money Laundering?
The act of concealing or disguising (laundering) of funds obtained through illegal activity
so that they appear to have been generated through legal, legitimate sources.
How is it Carried Out?
Shell companies, intermediaries and money transmitters usually transfer these funds around the world Banks and other financial institutions are the chosen medium for laundering these illegal funds
AML Regulations:
The Bank Secrecy Act is the most important Anti-Money Laundering (AML) regulation
The BSA requires financial institutions to:
Keep records of cash purchases of negotiable instruments
File reports of cash transactions exceeding $10,000 (daily aggregate amount)
Report suspicious activity that might signify money laundering, tax evasion, or other criminal activities
Implement a written, board-approved compliance monitoring program
The USA Patriot Act
Expands AML requirements to all financial institutions
Augments existing BSA framework
AML Best Practices:
In order to combat money laundering, banks should implement the following best practices:
Customer Identification Program (CIP)
Customer Due Diligence (CDD) Program
Bank Secrecy Act/Anti-Money Laundering Risk Assessment
Identification and Reporting of Suspicious Activity
Want to learn more about anti-money laundering process and best practices? ComplianceOnline webinars and seminars are a great training resource. Check out the following links:
http://www.complianceonline.com/anti-money-laundering-aml-compliance-program-seminar-training-80114SEM-prdsm?channel=amlppt
http://www.complianceonline.com/bsa-aml-ofac-risk-assessments-regulatory-requirements-seminar-training-80181SEM-prdsm?channel=ppt
http://www.complianceonline.com/bsa-aml-compliance-reporting-requirements-webinar-training-703352-prdw?channel=amlppt
http://www.complianceonline.com/bsa-aml-compliance-checklists-webinar-training-703178-prdw?channel=amlppt
http://www.complianceonline.com/bsa-aml-ofac-risk-assessments-and-evaluation-compliance-program-webinar-training-703493-prdw?channel=amlppt
http://www.complianceonline.com/best-practices-for-developing-risk-models-for-aml-bsa-monitoring-webinar-training-703628-prdw?channel=amlppt
This presented is aimed at AML/CTF practitioners who would need quick reminders of the basics of AML. Tools are not very useful if the underlying basics are unknown.
Introduction to Know Your Customer (KYC)LoanXpress
Â
Know your customer (KYC) is the process of a business, identifying and verifying the identity of its clients. The term is also used to refer to the bank regulation which governs these activities.
This is my presentation about what is money laundering crime and what is the role of financial institutions in the fight against it. I used it during my speech for a bunch of Business School Students (ISM).
Presentation given for Crowe Horwath Auditor's training session on 26/03/2016.
AML regulations are applicable to professional service providers also. See the presentation for more information
Temaswiss' Integrated Key Risk Controls (IKRC) best-practice design for Commercial Banking KYC and AML Transactions Monitoring.
- Commoditised Consulting & FSI Advisory packages.
- Tailored to your data & process realities.
- Budget- & Time-bound.
Introduction to Know Your Customer (KYC)LoanXpress
Â
Know your customer (KYC) is the process of a business, identifying and verifying the identity of its clients. The term is also used to refer to the bank regulation which governs these activities.
This is my presentation about what is money laundering crime and what is the role of financial institutions in the fight against it. I used it during my speech for a bunch of Business School Students (ISM).
Presentation given for Crowe Horwath Auditor's training session on 26/03/2016.
AML regulations are applicable to professional service providers also. See the presentation for more information
Temaswiss' Integrated Key Risk Controls (IKRC) best-practice design for Commercial Banking KYC and AML Transactions Monitoring.
- Commoditised Consulting & FSI Advisory packages.
- Tailored to your data & process realities.
- Budget- & Time-bound.
Customer is an important "entity" and is vital for existence of any business. Therefore it is so important to "Know Her".
The presentation which I created for interaction with students at a business school talks about same. It has examples which i have shared from my learnings which anyone in field of marketing, business and brands can relate easily.
Custody Banking and Emerging KYC NeedsTodd Breeden
Â
Presentation prepared for one of the world's largest custodian banking service providers summarizing macro trends affecting the landscape and how to focus on emerging technology vendors in RegTech as a potential strategic solution to expand their business footprint
Bovill - the UK financial services regulatory consultancy - runs regular briefings. These are the slides from the February briefing on anti-money laundering. For more information visit http://www.bovill.com/FinancialCrime.aspx.
Information on the event is below:
Taking a company-wide approach to money laundering
âThe FCA has made it very clear that responsibility for the overall culture of firms sits at the top. We need leaders and senior managers within the industry to set the tone for how their staff behave.â
Tracey McDermott, Director of Enforcement and Financial Crime, FCA
The regulator has recently reiterated their intention to carry out further thematic and enforcement work in financial crime. However, many firms still have a fragmented approach to managing the risks of money laundering.
The responsibility for preventing financial crime is shared across the firm from the back office to the boardroom. Firms need to take a company-wide approach to tackling money laundering to ensure they are complying with regulation and managing risks effectively.
Bovillâs briefing looked at Anti-Money Laundering (AML), covering:
⢠Governance arrangements: as the foundation for effective communication and issue resolution
⢠Risk management: the difficulties of negotiating the right level of due diligence for higher risk customers and what tools can be used to help with this process
⢠Systems and controls: ensuring that these are fit for regulatory purpose and are appropriately maintained within your firm.
Implementing Anti-Money Laundering and Know Your Customer Managed Services So...accenture
Â
The financial services industry is experiencing increased scrutiny, prompting institutions to rapidly evolve their AML and KYC programs. Many firms are struggling to expand their operations accordingly, and addressing these issues calls for new approaches, including adapting a managed services model for AML and KYC functions. This presentation also covers how robotic process automation (RPA) opportunities for AML/KYC functions. For more on a managed services approach on AML and KYC, visit: http://bit.ly/2czFJ1U
Money Laundering could be explained as the process in which large amounts of money obtained from illegal activities conducted are created to be appeared as legitimate. Some examples of such illegal activities could be crimes such as drug trafficking, terrorist activities etc. Copy the link given below and paste it in new browser window to get more information on Money Laundering:- www.transtutors.com/homework-help/finance/money-laundering.aspx
The secret way to sell pi coins effortlessly.DOT TECH
Â
Well as we all know pi isn't launched yet. But you can still sell your pi coins effortlessly because some whales in China are interested in holding massive pi coins. And they are willing to pay good money for it. If you are interested in selling I will leave a contact for you. Just telegram this number below. I sold about 3000 pi coins to him and he paid me immediately.
Telegram: @Pi_vendor_247
what is the future of Pi Network currency.DOT TECH
Â
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Â
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
how can i use my minded pi coins I need some funds.DOT TECH
Â
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. đ I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
what is the best method to sell pi coins in 2024DOT TECH
Â
The best way to sell your pi coins safely is trading with an exchange..but since pi is not launched in any exchange, and second option is through a VERIFIED pi merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and pioneers and resell them to Investors looking forward to hold massive amounts before mainnet launch in 2026.
I will leave the telegram contact of my personal pi merchant to trade pi coins with.
@Pi_vendor_247
how can I sell pi coins after successfully completing KYCDOT TECH
Â
Pi coins is not launched yet in any exchange đą this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAYÂ you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers âĽď¸
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
NO1 Uk Black Magic Specialist Expert In Sahiwal, Okara, Hafizabad, Mandi Bah...Amil Baba Dawood bangali
Â
Contact with Dawood Bhai Just call on +92322-6382012 and we'll help you. We'll solve all your problems within 12 to 24 hours and with 101% guarantee and with astrology systematic. If you want to take any personal or professional advice then also you can call us on +92322-6382012 , ONLINE LOVE PROBLEM & Other all types of Daily Life Problem's.Then CALL or WHATSAPP us on +92322-6382012 and Get all these problems solutions here by Amil Baba DAWOOD BANGALI
#vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore#blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #blackmagicforlove #blackmagicformarriage #aamilbaba #kalajadu #kalailam #taweez #wazifaexpert #jadumantar #vashikaranspecialist #astrologer #palmistry #amliyaat #taweez #manpasandshadi #horoscope #spiritual #lovelife #lovespell #marriagespell#aamilbabainpakistan #amilbabainkarachi #powerfullblackmagicspell #kalajadumantarspecialist #realamilbaba #AmilbabainPakistan #astrologerincanada #astrologerindubai #lovespellsmaster #kalajaduspecialist #lovespellsthatwork #aamilbabainlahore #Amilbabainuk #amilbabainspain #amilbabaindubai #Amilbabainnorway #amilbabainkrachi #amilbabainlahore #amilbabaingujranwalan #amilbabainislamabad
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Poonawalla Fincorp and IndusInd Bank Introduce New Co-Branded Credit Cardnickysharmasucks
Â
The unveiling of the IndusInd Bank Poonawalla Fincorp eLITE RuPay Platinum Credit Card marks a notable milestone in the Indian financial landscape, showcasing a successful partnership between two leading institutions, Poonawalla Fincorp and IndusInd Bank. This co-branded credit card not only offers users a plethora of benefits but also reflects a commitment to innovation and adaptation. With a focus on providing value-driven and customer-centric solutions, this launch represents more than just a new productâit signifies a step towards redefining the banking experience for millions. Promising convenience, rewards, and a touch of luxury in everyday financial transactions, this collaboration aims to cater to the evolving needs of customers and set new standards in the industry.
If you are looking for a pi coin investor. Then look no further because I have the right one he is a pi vendor (he buy and resell to whales in China). I met him on a crypto conference and ever since I and my friends have sold more than 10k pi coins to him And he bought all and still want more. I will drop his telegram handle below just send him a message.
@Pi_vendor_247
2. Content
⢠Concepts
⢠Process how it happens
⢠Basis for the requirement to have a Compliance Officer
Case
⢠Case Studies -Abroad
⢠Initiatives taken
Scenario-
India
⢠KYC (Know your customer)
⢠Case Studies
3. PML(Prevention of Money Laundering) Act, Sec.3
of 2002 defines âmoney launderingâ as:
âAnyone who, directly or indirectly, tries to deliver or
knowingly aid or knowingly is part or is actually
involved in any process or activity connected with the
products of the crime and its projection as pure
property must be guilty of the offense of laundering
the moneyâ
4. Is to conceal criminal activities related to it, including the
crimes that it has generated as the traffic of narcotics, tax
evasion, corruption, extortion, circumvent the regulations
etc
The process by which criminals seek to conceal the origin
and ownership of the products of criminal activities, in order
to avoid prosecution, conviction and confiscation of funds of
criminal origin(IBA definition)
The process by which the dirty money appear clean or
profits of criminal activities are made to the appearance of
legitimacy.
Concepts of Money laundering
5. Organized criminal groups use the money
laundering as a means to reinvest the money.
The main objective is to get the illegal funds back to
the individual or group of individuals who has
generated.
Financial intermediaries (banks, financial
institutions) are used to change the money
acquired from illegal businesses in acceptable and
transferable units, running illicit gain in legal course
Concepts - contd..
6. Concepts - contd..
AML
generally
refers to
âwashingâ of
the proceeds
or profits
generated
from:-
Drug
trafficking
smuggling
Financial
frauds
Arms,
Antique and
gold
smuggling
Illegal sale
of wild life
products
and others.
Prostitution
rings
Corruption
7. Concepts of Money laundering
For the âaverageâ criminal: money laundering is the
process by which the proceeds of criminal activity are
made to appear legitimate
For the âaverageâ Terrorist: money laundering is the
process by which money used to fund terrorist activity is
moved without revealing its true source, destination or
purpose
For âaverageâ tax evader: money laundering is the
process of spending money without leaving a trail showing
who owns it
8. Concepts - contd..
2%-5% of Global GDP is laundered every year
$800 Billion to $2 Trillion.
Financial powers
Most wanted criminals
Use the nexus pool of professionals to create
legal structure/ entities which act as a front
9. Money laundering is diversified and a complicated
process that involves three stages independent who
often occur simultaneously
Money Laundering Process
10. Step 1 - Placement
Physically the elimination of species from illegal
activities.
Funds are placed near the underlying activity in
the countries where the funds come from.
One of the ways to do this is by placing the
proceeds of criminal activities in traditional
financial institutions or non financial institutions
such as the offices of exchange, casinos.
11. Money Launderer inserts the
dirty money in a financial
institution is legitimate.
In the form of cash deposits.
To report high transactions.
This step is the most risky of the process of money laundering because
large quantities of species are fairly visible and banks are required
The placement
12. Step 2 - Layering
Separate the product of a criminal
activity of their source through the use
of layers of financial transactions.
These layers are designed to impede
the audit trail, disguise the origin of
funds and provide the anonymity
They use of shell corporations, offshore
banks or countries without or with less
regulation, a large business center.
13. Involves the sending of money through various financial operations
to change its form and make it difficult to follow.
The Layering can be comprised of several transfers from bank to
bank
Electronic funds transfers between different accounts in different
names in different countries
Make the deposits and withdrawals of continually vary the amount
of money in the accounts
Change the currency of the money
The purchase of high value items (cars, boats, houses diamonds) to
change the form of the money-making it difficult to trace.
Step 2 - Layering
14. Place the laundered proceeds in the economy
in such a way that they return to the financial
system as a fund apparently legitimate.
The launderer may choose to invest in other
centers.
Eg. False invoices for the goods exported,
ready against a deposit abroad, the purchase
of properties, etc.
Step 3 - Integration
15. At the integration stage the money returned to mainstream economy in legitimate form it
appears as a legal operation. This may involve the bank transfer final on an account of a
local company in which the launderer invests in exchange for a reduction of profits., the
sale of a yacht purchased during the phase of the stacking. At this stage, the criminal can
use of the money without be taken. It is difficult to catch a launderer during the phase of
integration is there is no documentation during the previous steps
Banks abroad
Money launderers often send money through various offshore accounts in the countries
which have laws protecting the Banking Secrecy -These countries allow anonymous
transactions. A complex scheme can involve hundreds of bank transfers and offshore banks
.according to the International Monetary Fund ,"offshore centers important iclude
Bahamas, Bahrain, Hong Kong, the Cayman Islands, the Netherlands Antilles, Panama and
Singapore (IMF)
Step 3 - Integration
16. Types/Techniques
Debit/Credit Cards
Deposit structuring (or
smurfing)
Connected accounts â
Connected to each other
Alternative Remittance
services âthe hawala
route
Loan back arrangements
Forex money changers
Investment banking
and the securities
sectors
Insurance and personal
investment products
Correspondent banking
Lawyers, Accountants and
other intermediaries
Mis-use of non-profit
organizations
Use of âPayable through
accountsâ by international
launderers
17. Money laundering through electronic
systems/cross-border activities
⢠Organized criminals can break in the
electronic security systems more
easily and at lower costs by forcing
the employees who have a legitimate
access to the system to provide them
with passwords.
Computers/electronic
systems can be used as
a tool to commit illegal
or criminal activities .
⢠Money launderers seek the countries
where there are highly educated and
trained of Bank staff on a low salary
of the corrupt.
Easier to corrupt an
individual in a country
where the average
salary is low.
18. Legal Sources of financing of terrorist activities:
Collection of union dues
Sale of publications
Social cultural events
The solicitation of door to door, within the community
Appeal to the wealthiest members of the community
Donation of a part of the personal savings
19. Illegal sources
Kidnapping and extortion
The Smuggling
Of fraud, including fraud by credit card
Misuse of non-profit organizations and charities
Fraud, theft and burglary and
The drug trafficking
20. The use of shell corporations by the lawyers
Involvement of distinguished attorney and personalities
Responsible for the fixed costs for the money laundering of funds
The funds of customers have been transferred to his son offshore accounts
Moved to the destinations of the Caribbean and USA
Credit cards issued in false names to help customers remove the money through ATMS
21. The small banks and NBFCs
The Private Banking assistance provided by the structure of assistance to
employees and the smurfs to recycle funds in the bank accounts, usually
by deposits and of withdrawal heavily from the accounting. A few months
before the audit of the activity would stop with a small balance.
Done To avoid the suspicion and the Disclosure
Arrangements of ready a technical- the launderer usually transfers the
product of illegal activities to another country- removal then the product
as security Or g'tee for a bank loan- and then returned to original country -
gives the appearance of a genuine loan.
22. The accounts of transit
⢠They are deposits to view the accounts required to
the SIF by foreign banks. The foreign banks channel
all of the deposits and checks of its customers in an
account at the local bank. The foreign customers
have signing authority on the account as the holders
of a secondary account and could conduct
international banking transactions-normal defeats
KYC standards.
23. Case Study-Accounting splits
Services provided by many professionals such as accountants, lawyers, real estate agents are also
used as potential mechanisms to launder money.
Purchase of truck parts, has reduced the parts in countries sold for a profit. Has also purchased
real property.
The purchase of assets
Transferred the product abroad. Structured transactions
Wire Transfer
Stored in the office of the Accountant. Accountant of deposits split. Open Trust/personal
accounts
Accounting Firm
Regular Deposit of criminal proceeds of the sale of the drug receipts issued.
Two drug traffickers
24. Case Study-Insurance policies and real estate
Two European nationals
Purchase of Life insurance policies (Total value Rs 1,60,80,000)
Payment of premium
Policies put up as collateral (provided by a leasing company)
The offenders were brothers who were involved in the illegal
export/import of classic cars
Non banking institutions could also become conduits for money
laundering.
25. Reports/facts on the Laundering of Money
Approximate estimate - 2 to 5 % of GDP (1996) $600 billion to 2
trillion dollars each year.
The main sources of income of illicit drugs -only more important
generator of illegal funds
The banking sector- smurfing common
The shell companies-tool commonly used by lawyers and
accountants
The small banks and NBFCs used as assistance channels private
banking to the assistance given in the restructuring of the accounts-
26. Impact - on the economy
Unpredictable changes in the demand for currency
The risks to the banking system - the risk of harm to the reputation, legal risk,
operational risk, the risk of concentration.
The increase in the volatility of international capital flows
The increase in the volatility of exchange rates due to unforeseen circumstances
of transfers of property. transversal
Economic and political influence of criminals may modify the social systems, the
ethical standards
Crime can infiltrate financial organizations, officials/ Governments
Macro-economic situations
Money laundering poses a serious threat to the international community and
financial systems of the countries of the world
28. KYC â Know your Customer
Know Your
Customer Policy:
to screen Customers and
Suppliers
establish and enforce standards and steps to verify and document
Customer and Supplier information, including
identity and verify address of both
documentation verifying personal identity
documentation verifying corporate identity
check the OFAC (âTerroristâ) List
29. RBI KYC standards
Appointment of a chief agent
In order to assess, monitor and control the risks of money
laundering.
Receive information from branches and analyze information
The highest confidentiality to be maintained during the deposit
Reports for all branches are filed in a mode -manual and electronic
A summary report of cash transaction for the Bank as a whole are
met by the bank
30. Benefits of standards KYC
Sound KYC procedures have a particular relevance to the safety and
soundness of banks, in that:
- They help to protect the reputation of the banks and the integrity of the
banking systems in reducing the likelihood of banks for becoming an
instrument or a victim of financial crime and the suffering; the damage to
the correlative reputation
- They provide an essential part of the system of sound risk management
(base of identification, to limit and control the exposures to risks of assets
and liabilities)
31. KYC - Direction
Customer?
The one who maintains an account, establishes the business
relationship, on who's name account is maintained, the
recipient of accounts held by intermediaries, and the one
who carries potential risk through a transaction.
Your? Who should know?
- Director of Branch,
Audit Officer, official
surveillance, PO
Know?
What you
need to
know?
- true identity and
the effective
property of
accounts
- Permanent address,
registered and
Administrative address
32. KYC - Direction
Make reasonable efforts to determine the true identity and actual
ownership of the accounts;
Sources of Funds
Nature of the customers
What constitutes the activity of reasonable account?
Who is the client of your customer?
33. Elements of KYC
Policy on the acceptance by the customer
Procedure for client identification- Profile of the customer
Risk Classification of Accounts -- approach based on risk
The management of the risks
The continuous monitoring of the activity of the account
The Declaration of species and suspicious transactions
34. High risk clients
Non-bank financial institutions ( money transmitters, check the cashiers, changers
with whole share, sellers of stored value cards, brokers in Security & Resellers, etc. )
Travel Agencies / Property Dealers/ builders
And companies of expert professional advice
The exporters or importers of goods and services
Activity requiring a lot of liquidity e.g., retail stores, restaurants, casinos, second
hand car dealers, etc.
Off-shore companies
Non-profit organizations eg. Charities
35. High risk products
EFTs:
Both national and cross-border wire transfers carry
the potential risks of money laundering
Payment Gateways facilitate electronic transfers for the
customers of the banks located anywhere in the world
Check if it is regulated on the place of incorporation
Insist on the complete information on the payer with wire
Make the payment to the beneficiary through Account or DD
Keep a record of the transaction
Electronic banking services, which includes the services
offered by the Internet, credit cards.
The relations of private bank
The correspondent banking relationships
37. Measures to discourage the ML
Council and the monitoring of the management of the risks AML
An appointment a member of the senior management as main agent with
appropriate powers and resources at his command
Systems, Orders & Documentation - identify, assess and manage the risks of
money laundering
Make a report to the Council on the operation and effectiveness of the systems
and the control
Creating client profiles
Screening of employees before hiring and of those who have access to sensitive
information
The quality of the appropriate training to staff
Fast and timely reports of suspicious transactions
38. Suspicious Transactions â FIU (financial Intelligence Unit)-IND
A transaction if yes or no made in cash to a person acting in good faith.
Gives birth to a reasonable ground to suspect that he may be the
proceeds of crime
No economic justification or bonafide Purpose
The identity of the customer
False Identification of Documents
Exhibit of identity cannot be verified in a reasonable period of time
The accounts opened with names very close to those of other companies
already established
Customer History
Links with the known criminals
39. Suspicious Transactions - FIU-IND
Multiple Accounts
The transfer between the accounts of unexplained no justification
Unusual activity compared with past operations
Sudden activity in the Inactive Accounts
Activity incompatible with what he must wait for activity declared
Frequent purchase of drafts in cash
Categories of financial intermediaries -financial brokers. Merchant
bankers, Portfolio Manager
Large sums of money to be transferred abroad for Payment
Reports to the market rate.
40. FIU Directions
Only the banks and other financial institutions are required to report
suspicious transactions regularly to the financial intelligence unit
established under the authority of the Department of Finance.
Such transactions are transmitted by the FIU to the law enforcement
agencies of action after a careful review.
Financial intermediaries as real money changer, suppliers of money
transfer services, such as Western Union and payment gateways
International, including VISA and MasterCard cards are brought under
the amended version of the MLPA.
The India of its international obligations and empower the direction of
application of the Act to search for the premises immediately after
that the offenses are committed and the police have filed a report
41. IPO scam - India
Manipulation of primary market by donors and actors in the market by using
fictitious names.
The only person authorized to operate all of the accounts. The person was
also director in all societies
Current accounts opened in different companies on the same day in the same
bank branch
The failure to identify the identity and address of all directors of corporations
Identity using different spellings of disguised for the same name in different
businesses.
The presentations, nor obtained
Risk profiles not performed
Objective for the opening of a large number of accounts opened in the name
of a large number of holders of joint account not interrogated
Transfer of huge funds from companies account for individuals which account
was used to invest in the IPO
Poor monitoring and reporting system
42. Operational deficiencies
Factors that have facilitated the IPO scam are -
The presentations not obtained
Photographs not obtained
Failure to independently verify the identity and address of all the holders
of a joint account
Signatures not taken in the presence of BANK REPRESENTATIVE
Identity Administration/ Address Not Verified
Customer due diligence carried out by a subsidiary
44. SATYAM - number
The direction of application of the Act has registered a complaint against
Satyam Computer and its president-founder contaminated Ramalinga Raju
for alleged B the laundering of money.
The ED sources alleged that Raju had misappropriated funds from Satyam
in the purchase of nearly 50 plots in Qutbullahpur Medchal and near
Hyderabad
The ED has alleged that several hundreds of crores rupees had been
diverted from the Satyam Computer Accounts and had been invested in
the purchase of the land and other infrastructure Maytas.
The Directorate will go through the offers of the computer society and
check their authenticity including payments made to acquire companies
abroad.
The ED will also send a team to a few countries to investigate and obtain
documents of bank accounts opened In violation of the Indian laws
45. The high risk areas of AML
High-risk countries
The drug-producing
countries
Countries with high
levels of corruption
Countries linked to
the financing of
terrorism
High risk clients
The private money
transmitters
The money changers
Real Estate Brokers
The casinos,
gambling held
Non-profit
organizations -
Charities
Services to High
Risk
Wire Transfers
The Private Banking
Correspondent
banking
Electronic banking
services-internet,
Credit/Debit Cards
46. Risk Factors
Vulnerabilities
⢠The Entities may not be regulated
⢠The anonymity of the client(Secret)
⢠No relationship of face to face
⢠Anonymous funding(in the form of
promissory notes)
⢠Cross-border transfers
⢠Access to cash on a global scale through
ATMS
Possible mitigation measures
⢠The verification of the identity of
clients
⢠Limit the options of funding
⢠Limit the value of the card
⢠Monitor transactions
⢠Reporting of Suspicious Activity
⢠No direct cash by the ATM
47. Advise customers
⢠The Bank - Legislative Audit (Long Form Audit
Report)
⢠Concurrent audit
⢠KYC and AML checks
⢠DP (depository Participant) audits as by SEBI
Guidelines
⢠Audit of the broker in stock by SEBI Guidelines
Audits -