AML Guide for Exchange Houses

Anti- Money Laundering (AML)
Presented by : Abishek Jajoo

Table of Contents
Sn Contents Slide
1 Introduction 4
2 Money Laundering Universe 9
3 AML history and penalties 14
4 Stages of Money Laundering 18
5 AML Stage decoded 27
6 Know Your Customer 31
7 Combating AML: Regulatory Response 38
8 AML in Exchange House Sector 43
9 Foreign Exchange and Remittance Group 45
10 Red Flags in Exchange Houses Business 50
11 KYC due diligence 56
12 Case Studies 60
13 Risk Based approach for AML 64

Key Takeaways from Session
Understand
 Key Definitions &
Classifications of AML
 Pillars & Stages of
AML
Pillars of AML
including:
 Stages of AML
 Identify
examples of
suspicious
behaviour
Test Your
Understanding at
the end of course
 Understand the Risk
based approach for
AML
 Client Due Diligence &
Enhanced Due
Diligence
 AML Certificates
 AML responsibility
Matrix
 Someone new to AML
 New Staff
 Refreshers Course
Course Time:
1 Hour

Anti-Money Laundering
“He that is of the opinion money will do
everything may well be suspected of doing
everything for money.”
Benjamin Franklin

Money Laundering
“Money laundering is the process by which
financial proceeds obtained from unlawful
activities/sources ("dirty" money) is
integrated into the legitimate economy by
putting it through a series of transactions ,
so as to disguise the source of Funds.
Examples include Tax evasion, bribery,
fraud, Illegal arms sales, smuggling and
other activities of organized crime”*
What is Money
Laundering
* Thomson Reuters & FATF
Simply put, Money laundering is the processing of these unlawful proceeds to disguise their illegal origin
Money laundering happens in almost every country in the world, and a single scheme
typically involves transferring money through several countries in order to obscure its
origins

Terrorist Financing
“Terrorist financing provides funds for
terrorist activity. It may involve funds
raised from legitimate sources, such as
personal donations and profits from
businesses and charitable organizations, as
well as from criminal sources, as defined
above”*
What is Terrorist
Financing
* Fintrac, Canada
The objective is to disguise the source of fund or the recipient of the fund, since terrorists raise funds from
legitimate sources ( in small quantity), the detection and tracking of these funds becomes more difficult

Money Laundering – By Criminal
sector
Estimated Value
Trafficking
Smuggling
Piracy/Cyber
Crime
Drugs
Other
Type Value in $
Bn
Trafficking 121.50
Smuggling 156.60
Piracy / Cyber Crime 251.00
Drugs 105.00
Others 9.80
Total 643.90
Source: UNODC, The Globalization of Crime: A Transnational Organized Crime Threat Assessment, June 2010

AML – Methods & Techniques (1/3)
 Money launderer can use any medium to ensure they disguise the origin of money.
Although, banking remains the common channel for laundering, yet there are various
modes the launderers have used in the past to launder money. The summary has been
highlighted below:
Banking
Institutions
• Banks
• Investment Companies
Non Bank
Financial
Institutions
• Exchange Companies
• Insurance Companies
Non FI
Business
• Real Estate Agent
• Traders of Precious
Metals

 We have outlined below the common methods and techniques used by money
launderer:
Money remittance entities
Exchange companies
Insurance companies
Securities Broker
Securities Trader
Non-Banking FIs
Money orders and e-
transfers
Corresponding banks and
Concentration accounts
(the internet)
Private banking
Structured deposits or
structuring
Collusion within the bank
Banking
Institutions

 We have outlined below the common methods and techniques used by money launder
(Non FIs):
Casinos and other
gambling related
business
Traders in precious
holdings
Trust companies
and corporate
service providers
Notaries public,
lawyers, accountants,
auditors
Car sales companies
Investment and
merchandise
consultants
Real estate sector
Currency exchange
black market

3. AML – History & Penalties

Biggest AML Penalties
Big name AML fines
J.P.Morgan
Chase
$31.3 billion
Standard
Chartered
$1 billion
RBS
$1.5 billion
Goldman
Sachs
$2.2 billion
HSBC
$3.5 billion
BNP PARIBAS
$2.99 billion

AML Penalties year wise / category wise

Few Exchange Houses Penalties
May 30, 2017. On this day the UAE Central Bank ordered the closure of an unnamed
small exchange house after detecting irregularities. The exchange had 6 branches, 3
in Dubai, 2 in Abu Dhabi and 1 in Sharjah, which was owned by an Emirati and an
Asian. The Asian Man absconded with money collected from customers, who
complained that their remittance were not reaching destination.
Central Bank on May 9, 2013 revoked license of 2 money exchange companies stating
that the pair broke regulatory rules, committing major regulatory violations. The
two exchange houses were Al Hilal and Asia Exchange, the latter had been at the
centre of a row of non payment of workers wages and failed to transfer expatriate
remittances.

Case in point
Mr.X is a dealer in
selling illegal firearms
and has a buyer who
paid him in cash.
Depositing huge cash
would be difficult for
him, so what can he
do? He sets up a real
estate company and
opens a bank account
to deposit small
amount of money so
not to raise suspicions
Placement
He then transfers
the money to many
different accounts
in various
jurisdictions ( with
different names).
Layering
He then trades into
option from one of
these accounts and
from the proceeds
he buys a property ,
thereby integrating
the money and
making it legitimate
Integration

What is the aim of the ML?
Placement
To push the dirty
money into the clean
system through series
of small banking
transactions, so to
avoid suspicions
Layering
To disguise the origin
of funds for funding
the property, multiple
accounts in different
name set up.
Objective is to hide
the audit trail of the
transactions
Integration
To use the legitimate
money (proceeds
from options) for
conducting legitimate
transactions (buying
a property)
Hence, the aim of money launderer was to :
 To disguise the origin of the funds;
 To create a confusing audit trail so the authorities would find it hard to trace the
money ; and
 To use the money in an apparently legitimate transaction using apparently
legitimate funds.

What you should do?
Do not tip off
Ensure that you do not tip
off suspicions
transactions to the
customer, who can be a
potential money
launderer.
Report
Suspicions
You should always raise
flags and report
suspicions to your AML
officer if you feel the
transaction is unusual or
the customer is not
entertaining your request
for documents etc.
Do not assist
Do not assist the money
launderer if he/she
decline to provide
necessary documents for
building relationships
and update the
documents every 2 years

Case Study 1
Receptionist Instruction from Relationship Manager
to deposit money into a clients account
Does not feel
right. What
should I do?

Case Study 1
The receptionist is asked by a
relationship manager to deposit money
into a clients account.
The receptionist does not feel this is
right.
What should she do?
A – Do as instructed and keep quite
B – Inform her line manager that she
has been instructed to do so.
Her line manager is absent that day.
What should she do?
A – Do as instructed and keep quite
B – Talk to the MLRO and appraise him
that she has been instructed to do so.

Case Study 2
Relationship ManagerProspect
I will be unable to
provide you any details
of the source of funds
since my tax consultant
has advised against
disclosing any details.
You should be happy that
the money is coming
from a reputed bank.
What should I do. I
feel he is hiding
something. But the
amount is coming
from a reputed
bank.

Case Study 2
What Should the Relationship Manager do?
A) Work with the prospect and somehow on board the client
B) Inform the prospect that without the source of wealth information being provided, he cannot be
on boarded as a client.
C) Inform the prospect that without the source of wealth information being provided, he cannot be
on boarded as a client and also report the issue to the MLRO as a suspicious transaction.
Relationship manager has collected the prospects passport and other details during past meetings
but finds this non disclosure to be suspicious.
Relationship Manager meets a prospect and in the course of discussion the prospect informs him
about the inability to provide details regarding the source of funds in accordance with advice
provided by his tax consultant.

Stage I : Placement
Objective : Getting rid of holding the proceeds of illegitimate operations
Depositing smaller cash amounts in one or several accounts;
Purchasing cheques and then depositing the same into the bank;
Purchasing single-premium insurance policy without paying
attention to details and conditions for cancellation and
commissions;
Money smuggling over borders;
Buying precious/ valuable metals;

Stage II : Layering
Objective : to separate the illicit money from its original source
Buying shares and then reselling the same;
Issuing several complex bank transfers;
Issuing transfers against goods (letters of credit);
Debt repayment (financing/ credit cards);

Stage III : Integration
Objective : to legitimatize the money generated from illegitimate activities
through integrating the money into the financial system
Repurchasing precious valuable assets, properties, lands;
Entering into or financing business projects;
Buying goods;
Buying Bonds, equity etc.;

KYC
What should banks/Exchange
Houses do?
Checking if customer has necessary KYC documents would be the
first and most critical step

KYC - CBUAE
KYC Policy is the preemptive anti- money laundering measure to
halt any misuse of the exchange channel for money laundering.
The policy framework is intended to regulate the operations so
as to ensure the flow of only legal money through remittance
channels. The main aim is to:
1. Identify customers with true documentation that are
seeking to conduct transactions.
2. Be alert to any unusual transaction activity
3. To prevent the creation of fictitious accounts with
standardized procedures.

Customer Identity format
•Name of the Customer and DOB
•Nationality
•Permanent Address
•Telephone No.(Res & Off.)
•Purpose of transaction
•Passport No.
•NTN
•Nature of Business
•Bank Account

12. Details of Assets Owned:
a) Cash Value:
b) Stocks & Bonds Value:
c) Real Estate Value:
d) Other Value:
13. Details of Liabilities:
a) Loans / debts
b) Debit accounts
14. Source of Funds to be invested: _____________________________________________________________
15. Names of banks he deals with: ______________________________________________________________
16. Details should be mentioned if there is more than one account:
Applicant’s Name: _________________________ Capacity: ___________________
Signature: ________________________________ Date: ______________________
Approval of Production & Sales Manager
Name: ________________________
Signature: _____________________
Date: _________________________
Customer Identity format (continued)

KYC Remediation Program
Sl
No
CIP Documents List Yes No
1 Complete Name of the Client Yes
2 Client's MaidenName No
3 Address of the client Yes
4 Contactdetails Yes
5 DOB Yes
6 Various accounts maintained by the client No
7 Creditscore No
8 IdentificationNumber Yes
9 PassportDetails Yes
-Prepare a
list of all
clients.
-Categorize
according to
the industry
sector.
- Develop a
CIP
Checklist for
individual
clients and
entities.
-Collecting
the
documents
as per the
list.
-Prepare a
list of
missing and
expired
documents.
CUSTOMER IDENTIFICATION PROGRAM (CIP)
Develop CIP Checklist

Risk Based Approach – KYC remediation
RISK ASSESSMENT OF CLIENTS
Risk AssessmentFrequency
HighRisk
Documentswill
be reviewed
once in ayear
MediumRisk
LowRisk
Documentswill
be reviewed
once in three
years.
Documentswill
be reviewed
once in two
years.
After the CIP and document collection, we
need to risk access the clients as high,
medium and low on the basis of the following
categories:
• Country ofbusiness
• Industrysector
• Ownership
• Products
• Negative Alerts
• PEP and RCA connections.
KYC Risk Assessment Criteria
Accumulated
Score
Risk Grading Due
Diligence
1 to4 Low CDD
5 to8 Medium CDD
9 to12 High EDD
Indicator High Medium Low
Country of Business 3 2 1
IndustrySector 3 2 1
Ownership 3 2 1
Products 3 2 1
Negative Alerts 3 2 1
PEP & RCA Connections 3 2 1

7. Combating AML:
Regulatory Response

What is being done?
International
Efforts
UN Security Council Resolution No. 1373
and subsequent resolutions
FATF 40+9 recommendations
International Monetary Fund
(assessments, technical support, visits)
EU Directive & Basel Committee on
Banking Supervision
Wolfsburg Principles (corresponding
banks, private banking, trade finance)
Local Efforts
The UAE maintains a strong Anti Money
Laundering (AML) system.
Federal Law No. 4 of 2002
Federal Law No. 1 of 2004 and
Federal Law No. 9 of 2014

Financial Action Task Force (FATF)
The FATF is an intergovernmental organization established in 1989 by G7.
Originally it was referred as G-7 Financial Action Task Force.
G7 is an international forum for the member countries governments.
FATF is headquartered in Paris, France.
The mandate of the FATF is to set standards and to promote effective implementation of legal, regulatory and
operational measures for combating money laundering, terrorist financing and the financing of proliferation, and
other related threats to the integrity of the international financial system. In collaboration with other
international stakeholders, the FATF also works to identify national-level vulnerabilities with the aim of
protecting the international financial system from misuse.

Financial Action Task Force (FATF)
The new document is called the
FATF Recommendations 2012.
This revision was made in
order to combine each set of
principles intended to serve as
counter measures against
money laundering and terrorist
financing. This document is
meant to provide a set of
international standard that will
help to strengthen the integrity
of the financial system on a
global level.
In 2012, the FATF
combined two
documents, the Forty
Recommendations on
Money Laundering and
the IX Special
Recommendations.
The Forty
Recommendations on
Money Laundering was
initially released in 2000,
and was a document that
provides international
countermeasures against
money laundering. The IX Special
Recommendations was
meant to provide a
comprehensive set of
guidelines for the
prevention, detection and
combating of terrorism.

What the Recommendation requires
• Criminalize money laundering.
• Seize property to prevent further money laundering.
• Undertake customer due diligence (CDD) measures.
• Use enhanced due diligence in relationship with Politically Exposed persons (PEPs).
• Gather information about offshore institutions when conducting cross-border transactions.
• Create a Financial Intelligence Unit (FIU) for reporting suspicious transactions and to investigate
suspected cases of money laundering.
• Monitor operations to ensure compliance with AML legislation.
• Provide the authorities combating money laundering and terrorist financing with appropriate financing,
human and technical support.

• In recent years global efforts to prevent the abuse of financial
systems to launder money or finance terrorist activities have
become extremely important.
• Exchange Houses must follow certain set standards that must
be followed at all times in order to protect themselves from
being abused by money launderers and/or terrorist financiers
and to ensure Anti Money Laundering and Combating
Financing of Terrorism (AML/CFT) Compliance across its
business in line with UAE AML/CFT Laws and Regulations.

9. FOREIGN EXCHANCE AND
REMITTANCE GROUP

• Exchange companies in the UAE came together and formed the
Foreign Exchange and Remittance Group.
• The main objective is to work for the betterment of the
exchange industry and create a conducive environment for
their business growth and facilitate a healthy competitive
market for all.
• The group is licensed by the Dubai Chamber of Commerce &
Industry(DCCI) and works under the aegis of the Central Bank
of the UAE (CBUAE).
• The idea behind FERG has been to advocate for reform and
progress in our industry. The aim is to completely weed out
non-compliant financial transactions and unethical business
practices.
FERG

Money Laundering & Exchange Houses
Industry
Recently in these last few
years many cases have been
there not just worldwide
but also UAE of Money
laundering in the Currency
Exchange houses. With the
most recent one being in
May 2017.
The owner of an exchange
house took the remittance
deposited to be transferred
to another country and left
the country.

1.Beneficial Owners
2.On going Due
Diligence
3.Wire Transfers
4.Enhanced CDD on: A)FPEP’S
B)Correspondent
Banks
C)Businesses/
Individuals
5.Shell Banks and
Companies
6.Reporting of
suspicious
transactions
7.Attempted
Transactions
8.Unusual
Transactions
9.Tipping off 10.Compliance Officers
11.Penalty
Annexure to Circular No. 24/2000(Regulation concerning
Procedures for AML by CB to Money changers

Reputational loss
Financial loss/FinesLicense cancellation
Imprisonment
Risk of non-adherence
•As per Article 15 of the UAE Federal Law No. 4 of 2002, failure to report an STR to the
AMLSCU by those who are aware of the suspicious activity or transaction may be a
criminal offence, punishable by a fine or imprisonment or both.
•Under Article 16 of the UAE Federal Law No. 4 of 2002, tipping off is an offense and is
punishable for a fine or imprisonment or both.

10. Red Flags for Money
Laundering

Overview of Exchange House Sector
Money Exchange is a thriving business in the UAE owing
to a demographic structure which contains large number
of expatriates regularly transferring remittances to their
families and relatives in their home countries.
CB has issued Resolution No. 123/7/1992 dated
29.11.1992 for regulating money changers. One of the
most important provisions of the resolution confines
licensing for carrying on money changing houses to
institutions and companies established per provisions of
the commercial companies law.

Source: Mubasher
Exchange House Outward Remittance
(CBUAE 2017) Sector Q1
12.98
3.48
2.7 2 1.81
0
2
4
6
8
10
12
14
Amount(Billion)
Indian
Pakistan
Philippines
US
Egypt

Exchange Houses - Key Challenges
•Currency exchange houses engaged in money transfer
and foreign exchange business in UAE do face certain
challenges. The main challenge being that exchange
houses need to follow strict AML compliance
standards, else they are faced with potential fines and
in extreme cases a shutdown of the exchanges.
•Currency exchange houses in UAE is a very competitive
market as there are large number of players. This can
benefit the customers as the cost of remitting money is
very low compared to other countries but this can be a
bit of a problem for the exchange houses.

54
Red flags that indicates Money Laundering
Red flag is a signal that a transaction is unusual and suspicious. In general a few
red flags are:
•The client is known to have convictions for acquisitive crime.
• The client attempts to disguise the real owner of the business or the parties to the
transaction.
• The client asks for short-cuts and/or unexplained or unusual speed
• The finance is being provided by a lender, other than a financial institution, with no
logical explanation or economic justification
• A significant amount of private funding from an individual running a cash-intensive
business
• Business transactions involve countries where there is a high risk of money
laundering and/or the funding of terrorism.
• False or suspicious documents are used to back up transactions

Red Flags in Exchange Business
Customers altering transactions upon learning they must show ID
Customers reluctant to show ID
Customers trying to change large quantities of small value currency into large
value currency
Customers concealing the beneficial owner of funds
Company accounts whose transactions are mainly conducted in cash rather than
in negotiable instruments without an apparent reasons.
Repeated requests for travelers cheques or drafts in Foreign currency
Two customers coming together but sending money transfer separately to the same
beneficiary or coming together for receiving money transfer from the same remitter
*Above list is not exhaustive

Customer Due Diligence
Identify customer and
verify data, documents
and information
Determine if customer
is acting on behalf of
another person
Identify UBO and verify
identity of UBO
Obtain info on intended
nature of business and
relationship
On-going due diligence

Factors – Risk Profiling
1. Type and
background of
customer or UBO.
2. Geographical base.
3. Areas of operation.
4. Nature of activities
5. Means of payments.
6. Source of fund.
7. Source of Wealth.
8. Type & complexity
of business relation.
9. Any payments from
third parties.
10. Is business
relation dormant.
11. Bearer
arrangements.
12. Suspicion of ML, FT
or any crime.
*Above list is not exhaustive.

Unusual or Suspicious Exchange
Houses Transactions
All transactions with reasonable grounds for doubt – equal to or in
excess of prescribed limit – relating to ML, TF or unlawful
organization should be reported.
Disclosure to customer, beneficiary or any other party is prohibited,
other than authorities concerned with criminalization of ML and
combating TF. All employees should be conscious and aware of
issues related to any disclosure.
Competent employee must freeze transaction and notify AMLSC
Unit through electronics system or other reasonable means in case
of doubt of transactions being related to terrorism financing or
unlawful organizations.

A customer who
wants to send
money to his native
place to his
brother, goes to an
exchange house
and pays a sum of
AED 10,000.
The customer then
asks his brother 2
days later whether
the money reached.
The brother says
he hasn’t received
The customer then
enquires at the
exchange house.
The exchange
house is also
confused
On investigation it
is revealed that the
owner took the
money or an
employee stole the
money.
Case Study 1

• A customer comes to an Exchange house X to send money
abroad.
• The exchange house asks him for his ID proof. Upon asking the
customer realizes that he does not have the necessary ID with
him now.
• He tells the Exchange house that he is a regular customer and
that it is his first time he forgot. The exchange house agrees to
allow him to send money saying that this is the last time
• In such a situation the Exchange house is not following their
basic checklist and is prone to AML fine and AML penalties.
Case Study 2

• Exchange House X, does not follow proper AML guidelines.
• They do not do their annual internal AML audit and
manipulate the remittance fees so as to earn profit at
customers expense
• During the CB UAE AML audit, they are caught and fined a
huge amount.
• In fact the CB UAE warns them if they do not improve and
follow guidelines then by next year, their license would be
revoked.
Case Study 3

13. Risk Based approach for
AML

Risk Based Approach
Key elements:
• Identify any possible
risk relating to ML /
TF
Identification
• Countries, competent
authorities and
organizations have to
determine how the
ML/TF threats
identified will affect
Assessment
• Implies to take
enhanced measures
to manage and
mitigate situations
Mitigating
risks

Key success Factors
• Strong senior management leadership and oversight
of the development and implementation.Governance
• Adequate internal controls are a prerequisite for the
effective implementation of policies and processes to
mitigate ML/TF risk.
Internal controls
• Staff should have integrity, should be adequately
skilled and possess the knowledge and necessary
expertise.
Recruitment
• It is important that staff receive proper AML/CFT
trainingTraining
• Internal control environment should be conducive in
assuring the integrity, competence and compliance of
staff with relevant policies and procedures.
Ensuring and
monitoring compliance

Comprehensive Program
Core
Services
Risk Assessment & Monitoring
 Risk Cateogorisation of the Client into high, medium
and low
 Monitor the Clients on Risk Level Basis - high,
medium and low.
 Develop monitoring/trend reports along with
threshold for escalation
 Escalate/Report ot the Country Regulator if reqd
 SAR analysis and Implementation
Based on gap analysis:
 Development of checklist for collection of
missing/about to expire documents;
 Development of Controls checklist
 Perform CIP and than customer due
diligence on the clients.
 Implement IT Restructuring solutions.
Implementation & Training
 Conducting workshops/trainings for key
stakeholders in the process, including:
 Compliance Officer
 AML Manager.
 Risk Management Vertical.
 Front Office / Business
 IT Teams
 Provide continous support
 Carrying out On Going Reviews.
 Quality Assurance and Audit
Current State ”As Is” Analysis
 Collecting client’s information from the relation
manager & intranet.
 Diagnostic review of exisiting practices in
Compliance ,KYC and CIP practice.
 Review of the exisiting reporting and monitoring
structure.
 Review of the Exceptions and Variances

Risk Based Approach
RBA
Product/Services
Trading Account
OTC Deals
Derivatives
Geography
High Risk Country
Sanction Country
Medium or Low Risk
Customer
Individual
Citizen or Resident Expat
International Investor
Local Corporate
Listed
Partnership
Sole Proprietorship
International Entity
Listed
Unlisted
Trustee

Risk Based approach for AML
When a Corporate Relationship has been established, following process needs to be followed
The Relationship officer shall ensure the KYC form has duly filled by the
counterparty/customer. Based on the gathered information, it shall categorize
the customer into various risk categories
Know Your Customer
High Risk
Categorization of Risk
Medium Risk Low Risk
Enhance Due Diligence
at transaction level
Due Diligence
Simplified Customer
Due Diligence
Simplified Customer
Due Diligence
Trend Reports, Risk
Variables for HRC
Monitoring Tools
Trend Reports, Risk
Variables for MRC
Trend Reports, Risk
Variables for LRC
Every 2 yearsFrequency of Updating Customer
Information
Every 3 years Every 5 years
Enhance Due DiligenceDue Diligence, Incase of Suspicious
Transaction
Enhance Due Diligence Enhance Due Diligence
Define Thresholds ,
trend reports etc.
Define criteria based on
Customer Profiling
Define thresholds,
trend reports etc.
Define thresholds,
trend reports etc.

Suspicious Activity
Financial transactions that are inconsistent with the type of customer or business
they carry on. Examples of suspected transactions include:
 Usage of ATMs;
 Small/ structured cash deposits;
 Multiple remittances;
 Creating speculations/ deposits and then breaking the same regardless of the
fees;
 Sudden increase in volume of deposits;
 Opening deposits or investments using drafts with huge values;
 Insurance and funds;
 Unexpected repayment of debts; or
 Single customer has several accounts with no valid reasons.

OFAC/ Black List/PEPs – High Risk
Customers
 Current or former senior official in the executive, legislative,
administrative, military, or judicial branch of a foreign
government (elected or not)
 A senior official of a major foreign political party
 A senior executive of a foreign government owned commercial
enterprise, and/or being a corporation, business or other entity
formed by or for the benefit of any such individual
 An immediate family member of such individual; meaning spouse,
parents, siblings, children, and spouse's parents or siblings
 Any individual publicly known (or actually known by the relevant
financial institution) to be a close personal or professional
associate

AML Compliance Certificates
 AML compliance is not a point in time exercise and ongoing
monitoring should be done to establish a robust AML process. In this
regards, divisions should provide their assurance to AML division.

AML Responsibility Matrix
 Major O/S AML issues should be addressed through a clear responsibility
matrix so as to drive the right risk behavior in the your company.
 Accountability & Transparency promotes effective corporate governance
Primary
Responsibility
 Primary Responsibility for
managing the AML remains
with the relationship officer
of a business divisions.
 He/ She should report
suspicious transaction to
MLRO
Secondary
Responsibility
 A firm should promote
four eye principle i.e.
maker/checker concept to
avoid negligence, fraud
etc.
 Immediate Manager shall
also be responsible to
ensure suspicious
transactions are being
reported
Oversight
Authority
 Anti-Money
Laundering/
Compliance Unit should
act as an oversight
authority and should
independently also
review/audit the
transactions to ensure
all suspicious are being
reported.

AML Guide for Exchange Houses

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Similar to AML Guide for Exchange Houses

Similar to AML Guide for Exchange Houses (20)

Recently uploaded

Recently uploaded (20)

AML Guide for Exchange Houses