This document discusses politically exposed persons (PEPs) and anti-money laundering practices related to PEPs. It defines PEPs as individuals who hold or have held prominent public positions in foreign governments. While state-owned enterprises are not considered PEPs, senior individuals who manage them could qualify as PEPs. Banks should have risk management systems to identify PEP customers and apply enhanced due diligence, such as obtaining senior management approval and assessing the source of wealth. One typically remains considered a PEP for one year after leaving a political position. Banks can do business with PEPs by applying enhanced scrutiny and monitoring the relationship. Focusing on PEPs helps combat corruption and money laundering risks.
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
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
Money Laundering and Terrorist Financing in a Nutshell: Chapter OneMd. Moulude Hossain
Financial Crime is an increasing concern for all financial institutions, which is developing rapidly and equally together with technology. May be not limited to money laundering and terrorist financing, these two form of financial crime deserve to be attended with utmost care.
The evolving challenges of Money Laundering (ML) and Terrorist Financing (TF) lead the evolution of anti-money laundering and counter terrorist financing convention and regulations. These conventions give birth of several international organizations to combat the impact of ML and TF.
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
E-book: How to manage Anti-Money Laundering and Counter Financing of Terroris...Jitske de Bruijne
Financial Institutions continue to face heightened fines and regulatory scrutiny over their AML/CFT Programs. This e-book helps you to manage AML/CFT Programs.
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.
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).
European Payment Summit presentation delivered by Nadja van der Veer of PaymentCounsel and Michael Burtscher of Minerva on 15 March 2018.
The presentation explored current issues around the regulation of cryptocurrencies, focusing on the following topics:
Cryptocleansing: how does it work?
Market concerns & regulatory responses
The road to crytpo licensing: learning from New York
Cryptoplatforms: success through compliance
To receive a copy of this presentation by email please get in touch: hello@minervapartnership.eu
Money Laundering and Terrorist Financing in a Nutshell: Chapter OneMd. Moulude Hossain
Financial Crime is an increasing concern for all financial institutions, which is developing rapidly and equally together with technology. May be not limited to money laundering and terrorist financing, these two form of financial crime deserve to be attended with utmost care.
The evolving challenges of Money Laundering (ML) and Terrorist Financing (TF) lead the evolution of anti-money laundering and counter terrorist financing convention and regulations. These conventions give birth of several international organizations to combat the impact of ML and TF.
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
E-book: How to manage Anti-Money Laundering and Counter Financing of Terroris...Jitske de Bruijne
Financial Institutions continue to face heightened fines and regulatory scrutiny over their AML/CFT Programs. This e-book helps you to manage AML/CFT Programs.
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.
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).
European Payment Summit presentation delivered by Nadja van der Veer of PaymentCounsel and Michael Burtscher of Minerva on 15 March 2018.
The presentation explored current issues around the regulation of cryptocurrencies, focusing on the following topics:
Cryptocleansing: how does it work?
Market concerns & regulatory responses
The road to crytpo licensing: learning from New York
Cryptoplatforms: success through compliance
To receive a copy of this presentation by email please get in touch: hello@minervapartnership.eu
Typologies in general examined -
Securities
Trade Based
Counterfeit Trade
Sports Clubs (and Equestrian)
Child Pornography & Human Trafficking
Government Contracting / Bribery / PEPs
Internet Based Market Systems
Currency Demand Approach
Pricing Approach
Multiple Indicators Multiple Solutions (MIMIC)
Measurement of Crimes Model
Newton’s Law of Gravity applied to ML
How to conduct an anti-money laundering (AML) system assessmentKeith Furst
This presentation was given on October 4, 2016 at the Toronto Marriott Downtown Eaton Centre Hotel at the 14th installment of Canada’s premier event in the field of money laundering compliance and control. The theme of Money Laundering in Canada 2016 is Financial Crime, Compliance, and Regulation: Keeping Pace with the Times.
A robust risk assessment process is central to maintaining a strong Anti-Money Laundering (AML) compliance program. In this new Accenture presentation we explore how financial services firms can set-up an effective process. Visit our fraud and financial crime blog post for more on AML risk assessment program: http://bit.ly/2aPlQQ7
FATF's June 2013 Guidance Note on a Risk Based Approach to Implementing AML/C...Louise Malady
Understanding and using FATF's June 2013 Guidance note of a Risk Based Approach to Implementing AML/CFT Measures for mobile money and other new payment methods
An immersive workshop at General Assembly, SF. I typically teach this workshop at General Assembly, San Francisco. To see a list of my upcoming classes, visit https://generalassemb.ly/instructors/seth-familian/4813
I also teach this workshop as a private lunch-and-learn or half-day immersive session for corporate clients. To learn more about pricing and availability, please contact me at http://familian1.com
Consumer Financial Protection Bureau presents an overview of financial elder abuse at the LiveOn NY 26th Annual Conference on the Transformation of Aging. The presentation includes a link to an interactive online tool that includes an "older americans" tag focusing on issues of interest to older adults, links to a section where consumers can input complaints and CFPB works to get answers from companies on these complaints. There is also an office for Older Americans whose mission is to help consumers 62+ get the financial education and training they need.
A UBO is an individual who ultimately owns or controls 25% or more
of an entity (whether directly as a shareholder or indirectly via control
of companies) or other entities or structures that control the entity. In
short, it is the ultimate beneficiary regardless of the chain of control.
All product and company names mentioned herein are for identification and educational purposes only and are the property of, and may be trademarks of, their respective owners.
Knowing Your Customers: Pinpointing Patterns for Increased VigilanceJay Postma
October 8, 2014 presentation before International Money Transmitters Conference - Miami by John Schmarkey, CAMS, CFE and Jay Postma, CAMS. Covering Customer Identification, Due Diligence, Culture of Compliance, identifying and understanding customers, etc.
Financial Market Failure and Regulation of the Financial Systemtutor2u
This is a study presentation on different causes of financial market failure and also policies introduced designed better to regulate the activities of the financial sector.
Snam 2023-27 Industrial Plan - Financial Presentation
Anti money laundering - PEPs
1. ANTI MONEY
LAUNDERING
P O L I T I C A L LY E X P O S E D P E R S O N S
Presented by:
Besart Qerimi
besart.qerimi@gmail.com
2011
2. SESSION OBJECTIVES
• Defining PEP's
• Basic considerations
• Others associated with PEPs
• Sleeper PEP's
• When does one lose status as a PEP?
• PEPs Risks
• Banks and awareness of the problem
• Can we do business with a PEP?
• State-owned enterprises be considered PEPs?
3. DEFINING POLITICALLY EXPOSED
PERSONS
“Politically Exposed Persons”(PEPs) are individuals who are or have been entrusted
with prominent public functions in a foreign country, for example Heads of State or of
government, senior politicians, senior government, judicial or military officials, senior
executives of state owned corporations, important political party officials. Business
relationships with family members or close associates of PEPs involve reputational risks
similar to those with PEPs themselves. The definition is not intended to cover middle
ranking or more junior individuals in the foregoing categories.”
Financial Action Task Force
4. SHOULD STATE-OWNED ENTERPRISES
BE CONSIDERED PEPS?
• State-owned enterprises, including
central banks, should not be considered
PEPs.
• The individuals who manage and run
the state-owned enterprise at senior
levels, however, could qualify as PEP
• All state-owned enterprises are not
necessarily low risk, such entities should
be assessed using appropriate risk
factors.
5. HOW CAN A PEP OR THEIR “CLOSE FAMILY OR
ASSOCIATES” BE IDENTIFIED?
• Making enquiries regarding PEP status
of potential customers during the
account opening process
• Screening potential customers against
a database of such persons. (e.g.
developed internally, provided by an
external service provider-world check,
down jones)
6. FINANCIAL INSTITUTIONS
• Financial institutions should, in relation to politically exposed persons, should:
• Have appropriate risk management systems to determine whether the
customer is a politically exposed person
• Apply appropriate enhanced procedures and controls
• Obtain senior management approval
• Take reasonable measures to establish the source of wealth and source of funds
• Conduct enhanced ongoing monitoring of the business relationship
• PEPs are a special category of customers, all designated as high risk for money
laundering.
New FATF Recommendation 12
7. APPLYING A RISK-BASED APPROACH
• It is flexible
• It is effective
• It is proportionate
8. HOW LONG DOES ONE REMAIN A PEP?
• The Wolfsberg Group provides the
following insight into its interpretation
of the „expiration date‟ on a PEP:
“Rule of thumb“: 1 year after giving up
any political function.
• The latest EU working paper on the
Third Money Laundering Directive
and FATF do not mention any time
limit.
9. CAN I DO BUSINESS WITH A PEP?
• Of course you can, but with enhanced due diligence and heightened scrutiny.
• UNCAC, Article 52 (entered into force Dec 2005):
“to conduct enhanced scrutiny of accounts sought or maintained by or on behalf of
individuals who are, or have been, entrusted with prominent public functions and
their family members and close associates.”
No legislation says financial institutions are not allow to open accounts for PEPs
What is the „real‟ reason to carry out effective PEP due diligence?
The answer is simple: REPUTATIONAL DAMAGE
10. WHY FOCUS ON PEPS?
• Represent a greater money laundering risk because of the possibility that they
will abuse their position and influence to carry out corrupt acts (e.g.,
corruption and bribery, steal assets).
• $1 trillion in bribes each year (World Bank estimate).
• Corrupt PEPs are becoming more effective in hiding their identity through
associates, legal entities, and intermediaries.
• Low numbers of PEP customers are not necessarily indicative of low numbers
of corrupt PEPs.
“Not all PEPs are bad” but all require Enhance Due Diligence
11. WHY FOCUS ON PEPS?
The FATF consultation paper quoted in point 3 clearly indicates
that a PEP with „something to hide‟ may well choose to
conceal his or her identity by using some form of corporate
structure. This is with the greatest certainty where financial
institutions are most likely to find the skeletons in their closets.
12. WHAT ARE SOME OF THE
CHALLENGES?
• Corruption exploitation
• Inadequate regular reviews of high-risk and PEP customers in order to update
CDD
• Keeping AML policies and procedures up-to-date
• Inadequate EDD on family members or close associates of PEPs
• No corrupt PEP activity in banks or in other sectors
• Few PEP STRs
• Few investigations or prosecutions for grand corruption
• Identifying national and international PEPs
Where is the corrupt money?
13. HAVE YOU TRULY UNDERSTOOD YOUR PEP REQUIREMENTS, IDENTIFIED YOUR
PEP RISK AND HAVE YOU SET OUT TO IMPLEMENT A PEP POLICY THAT WILL
PROTECT YOUR INSTITUTION, ITS REPUTATION AND INDEED, YOUR JOB?