The document discusses money laundering and proceeds of crime regulations in Zimbabwe, focusing on the duties and penalties for financial institutions and designated non-financial businesses under the Proceeds of Crime Act ("POCA"). It provides an overview of prohibited money laundering activities, the roles of relevant organizations like the Financial Intelligence Unit, and recommends actions for the Chartered Secretaries Zimbabwe to educate members and regulate the industry.
Anti money laundering and combating the financing of terrorism (AML/CFT) REGU...Bilal khan
UPTO DATE AND ACCORDING TO PAKISTAN'S STATE BANK REGULATIONS AND REQUIREMENTS FOR ANTI MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM WITH INTERNATIONAL STANDARDS
Prevention of Money Laundering Act 2002ramandeepjrf
Prevention of money laundering act 2002
Definitions, Obligation for Banks, Financial Institutions, Intermediaries, Attachment, Adjudication and confiscation of property, Appellate Tribunal, Special Court, Penalty and fine.
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
Anti Money Laundering regulations in Kenya and how they impact businesses especially in light of the introduction of new currency notes, especially the Kshs 1,000 note, and the CBK's Governors statement on the Launch of the new currency notes.
Anti money laundering and combating the financing of terrorism (AML/CFT) REGU...Bilal khan
UPTO DATE AND ACCORDING TO PAKISTAN'S STATE BANK REGULATIONS AND REQUIREMENTS FOR ANTI MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM WITH INTERNATIONAL STANDARDS
Prevention of Money Laundering Act 2002ramandeepjrf
Prevention of money laundering act 2002
Definitions, Obligation for Banks, Financial Institutions, Intermediaries, Attachment, Adjudication and confiscation of property, Appellate Tribunal, Special Court, Penalty and fine.
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
Anti Money Laundering regulations in Kenya and how they impact businesses especially in light of the introduction of new currency notes, especially the Kshs 1,000 note, and the CBK's Governors statement on the Launch of the new currency notes.
The Prevention of Money Laundering Act, 2002 (PMLA) is an Act to prevent money-laundering and to provide for confiscation of property derived from, or involved in, money-laundering. In this webinar, we shall analyse and understand the various provisions of the Act covering the meaning of Money Laundering, the consequences and the procedures involved.
MoCI Ministerial Decree 412 FY13 with regards controls and instructions regul...Warba Insurance Co Kuwait
Kuwait Ministry of Commerce & Industry Ministerial Decree 412 FY13 with regards controls and instructions regulating the working of insurance companies brokers and agents especially with regards combating money laundry and terrorism financing
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.
I came to know many fraudulently run organizations which take money from people by promising huge returns and later run away. Here is a brief about laws in India to prevent such acts.
Learn more about Government Initiatives and Reporting Requirements surrounding the response to the growth of cryptocurrency markets. watch our full webinar on the topic at web address to learn more about the topic
Anti Money Laundering's regulation: current aspects and future forecastsclaudiotarulli3
Presentazione della Tesi "Anti Money Laundering's regulation: current aspects and future forecasts" presentata per il Master in "Antiriciclaggio e Compliance" presso la European School of Banking Management.
The Prevention of Money Laundering Act, 2002 (PMLA) is an Act to prevent money-laundering and to provide for confiscation of property derived from, or involved in, money-laundering. In this webinar, we shall analyse and understand the various provisions of the Act covering the meaning of Money Laundering, the consequences and the procedures involved.
MoCI Ministerial Decree 412 FY13 with regards controls and instructions regul...Warba Insurance Co Kuwait
Kuwait Ministry of Commerce & Industry Ministerial Decree 412 FY13 with regards controls and instructions regulating the working of insurance companies brokers and agents especially with regards combating money laundry and terrorism financing
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.
I came to know many fraudulently run organizations which take money from people by promising huge returns and later run away. Here is a brief about laws in India to prevent such acts.
Learn more about Government Initiatives and Reporting Requirements surrounding the response to the growth of cryptocurrency markets. watch our full webinar on the topic at web address to learn more about the topic
Anti Money Laundering's regulation: current aspects and future forecastsclaudiotarulli3
Presentazione della Tesi "Anti Money Laundering's regulation: current aspects and future forecasts" presentata per il Master in "Antiriciclaggio e Compliance" presso la European School of Banking Management.
Money Laundering: A Three Step Secret GameMd Arman
This paper describes, theoretically, what money laundering is and how it is done following some
partnered activities over time. This paper also looks for electronic money laundering and found some
related and predefined functions which are completed using electronic gadgets and the Internet. To give
a clear view on money laundering, the author thinks that it is necessary to make it clear first about the
characteristics of money laundering, the reasons behind it, and how it creates negative impacts on the
business and economy of a country. In most nations, it is a crime and economically developed countries
built strong fortress against money launderers but laundering is not stopped. So, this paper tries to discover
out what and how the launderers launder and discover inventive ways to form their unlawful cash lawful
which the legal authority can not detect. This paper shows the step by step procedures of this globally
illegal money whitening activities mostly theoretically
Understanding Anti-Money Laundering_ A Comprehensive Guide.pdftewhimanshu23
Explore the essential aspects of Anti-Money Laundering (AML) with our comprehensive guide. Learn key practices, regulations, and strategies. For more Information Read this article
Guidance on Beneficial Ownership
Anti-Money Laundering,
Countering Financing of Terrorism and Targeted Financial Sanctions for
Financial Institutions,
Designated Non-Financial Businesses and Professions and Non-Bank Financial Institutions
MONEY LAUNDERING: A THREE-STEP SECRET GAMEMd Arman
This paper describes, theoretically, what money laundering is and
how it is done following some partnered activities over time. This
paper also looks for electronic money laundering and finds related
and predefined functions completed using electronic gadgets and the
Internet. To give a clear view on money laundering, the author thinks
it is necessary to make it clear first about the characteristics of money
laundering, the reasons behind it, and how it negatively impacts the
business and economy of a country. Money laundering is a crime in
most nations, and economically developed countries built a strong
fortress against money launderers, but laundering is not stopped. So,
this paper tries to find out what the launderers do and find innovative
(legally unaccepted) ways to make their illicit money legal.
Zimbabwe Agenda for Sustainable Socio-Economic Transformation (ZimAsset) “Towards an Empowered Society and a Growing Economy” OCTOBER 2013- DECEMBER 2018
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
GraphRAG is All You need? LLM & Knowledge GraphGuy Korland
Guy Korland, CEO and Co-founder of FalkorDB, will review two articles on the integration of language models with knowledge graphs.
1. Unifying Large Language Models and Knowledge Graphs: A Roadmap.
https://arxiv.org/abs/2306.08302
2. Microsoft Research's GraphRAG paper and a review paper on various uses of knowledge graphs:
https://www.microsoft.com/en-us/research/blog/graphrag-unlocking-llm-discovery-on-narrative-private-data/
Search and Society: Reimagining Information Access for Radical FuturesBhaskar Mitra
The field of Information retrieval (IR) is currently undergoing a transformative shift, at least partly due to the emerging applications of generative AI to information access. In this talk, we will deliberate on the sociotechnical implications of generative AI for information access. We will argue that there is both a critical necessity and an exciting opportunity for the IR community to re-center our research agendas on societal needs while dismantling the artificial separation between the work on fairness, accountability, transparency, and ethics in IR and the rest of IR research. Instead of adopting a reactionary strategy of trying to mitigate potential social harms from emerging technologies, the community should aim to proactively set the research agenda for the kinds of systems we should build inspired by diverse explicitly stated sociotechnical imaginaries. The sociotechnical imaginaries that underpin the design and development of information access technologies needs to be explicitly articulated, and we need to develop theories of change in context of these diverse perspectives. Our guiding future imaginaries must be informed by other academic fields, such as democratic theory and critical theory, and should be co-developed with social science scholars, legal scholars, civil rights and social justice activists, and artists, among others.
DevOps and Testing slides at DASA ConnectKari Kakkonen
My and Rik Marselis slides at 30.5.2024 DASA Connect conference. We discuss about what is testing, then what is agile testing and finally what is Testing in DevOps. Finally we had lovely workshop with the participants trying to find out different ways to think about quality and testing in different parts of the DevOps infinity loop.
Builder.ai Founder Sachin Dev Duggal's Strategic Approach to Create an Innova...Ramesh Iyer
In today's fast-changing business world, Companies that adapt and embrace new ideas often need help to keep up with the competition. However, fostering a culture of innovation takes much work. It takes vision, leadership and willingness to take risks in the right proportion. Sachin Dev Duggal, co-founder of Builder.ai, has perfected the art of this balance, creating a company culture where creativity and growth are nurtured at each stage.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...DanBrown980551
Do you want to learn how to model and simulate an electrical network from scratch in under an hour?
Then welcome to this PowSyBl workshop, hosted by Rte, the French Transmission System Operator (TSO)!
During the webinar, you will discover the PowSyBl ecosystem as well as handle and study an electrical network through an interactive Python notebook.
PowSyBl is an open source project hosted by LF Energy, which offers a comprehensive set of features for electrical grid modelling and simulation. Among other advanced features, PowSyBl provides:
- A fully editable and extendable library for grid component modelling;
- Visualization tools to display your network;
- Grid simulation tools, such as power flows, security analyses (with or without remedial actions) and sensitivity analyses;
The framework is mostly written in Java, with a Python binding so that Python developers can access PowSyBl functionalities as well.
What you will learn during the webinar:
- For beginners: discover PowSyBl's functionalities through a quick general presentation and the notebook, without needing any expert coding skills;
- For advanced developers: master the skills to efficiently apply PowSyBl functionalities to your real-world scenarios.
PHP Frameworks: I want to break free (IPC Berlin 2024)Ralf Eggert
In this presentation, we examine the challenges and limitations of relying too heavily on PHP frameworks in web development. We discuss the history of PHP and its frameworks to understand how this dependence has evolved. The focus will be on providing concrete tips and strategies to reduce reliance on these frameworks, based on real-world examples and practical considerations. The goal is to equip developers with the skills and knowledge to create more flexible and future-proof web applications. We'll explore the importance of maintaining autonomy in a rapidly changing tech landscape and how to make informed decisions in PHP development.
This talk is aimed at encouraging a more independent approach to using PHP frameworks, moving towards a more flexible and future-proof approach to PHP development.
"Impact of front-end architecture on development cost", Viktor TurskyiFwdays
I have heard many times that architecture is not important for the front-end. Also, many times I have seen how developers implement features on the front-end just following the standard rules for a framework and think that this is enough to successfully launch the project, and then the project fails. How to prevent this and what approach to choose? I have launched dozens of complex projects and during the talk we will analyze which approaches have worked for me and which have not.
Essentials of Automations: Optimizing FME Workflows with ParametersSafe Software
Are you looking to streamline your workflows and boost your projects’ efficiency? Do you find yourself searching for ways to add flexibility and control over your FME workflows? If so, you’re in the right place.
Join us for an insightful dive into the world of FME parameters, a critical element in optimizing workflow efficiency. This webinar marks the beginning of our three-part “Essentials of Automation” series. This first webinar is designed to equip you with the knowledge and skills to utilize parameters effectively: enhancing the flexibility, maintainability, and user control of your FME projects.
Here’s what you’ll gain:
- Essentials of FME Parameters: Understand the pivotal role of parameters, including Reader/Writer, Transformer, User, and FME Flow categories. Discover how they are the key to unlocking automation and optimization within your workflows.
- Practical Applications in FME Form: Delve into key user parameter types including choice, connections, and file URLs. Allow users to control how a workflow runs, making your workflows more reusable. Learn to import values and deliver the best user experience for your workflows while enhancing accuracy.
- Optimization Strategies in FME Flow: Explore the creation and strategic deployment of parameters in FME Flow, including the use of deployment and geometry parameters, to maximize workflow efficiency.
- Pro Tips for Success: Gain insights on parameterizing connections and leveraging new features like Conditional Visibility for clarity and simplicity.
We’ll wrap up with a glimpse into future webinars, followed by a Q&A session to address your specific questions surrounding this topic.
Don’t miss this opportunity to elevate your FME expertise and drive your projects to new heights of efficiency.
State of ICS and IoT Cyber Threat Landscape Report 2024 previewPrayukth K V
The IoT and OT threat landscape report has been prepared by the Threat Research Team at Sectrio using data from Sectrio, cyber threat intelligence farming facilities spread across over 85 cities around the world. In addition, Sectrio also runs AI-based advanced threat and payload engagement facilities that serve as sinks to attract and engage sophisticated threat actors, and newer malware including new variants and latent threats that are at an earlier stage of development.
The latest edition of the OT/ICS and IoT security Threat Landscape Report 2024 also covers:
State of global ICS asset and network exposure
Sectoral targets and attacks as well as the cost of ransom
Global APT activity, AI usage, actor and tactic profiles, and implications
Rise in volumes of AI-powered cyberattacks
Major cyber events in 2024
Malware and malicious payload trends
Cyberattack types and targets
Vulnerability exploit attempts on CVEs
Attacks on counties – USA
Expansion of bot farms – how, where, and why
In-depth analysis of the cyber threat landscape across North America, South America, Europe, APAC, and the Middle East
Why are attacks on smart factories rising?
Cyber risk predictions
Axis of attacks – Europe
Systemic attacks in the Middle East
Download the full report from here:
https://sectrio.com/resources/ot-threat-landscape-reports/sectrio-releases-ot-ics-and-iot-security-threat-landscape-report-2024/
GDG Cloud Southlake #33: Boule & Rebala: Effective AppSec in SDLC using Deplo...James Anderson
Effective Application Security in Software Delivery lifecycle using Deployment Firewall and DBOM
The modern software delivery process (or the CI/CD process) includes many tools, distributed teams, open-source code, and cloud platforms. Constant focus on speed to release software to market, along with the traditional slow and manual security checks has caused gaps in continuous security as an important piece in the software supply chain. Today organizations feel more susceptible to external and internal cyber threats due to the vast attack surface in their applications supply chain and the lack of end-to-end governance and risk management.
The software team must secure its software delivery process to avoid vulnerability and security breaches. This needs to be achieved with existing tool chains and without extensive rework of the delivery processes. This talk will present strategies and techniques for providing visibility into the true risk of the existing vulnerabilities, preventing the introduction of security issues in the software, resolving vulnerabilities in production environments quickly, and capturing the deployment bill of materials (DBOM).
Speakers:
Bob Boule
Robert Boule is a technology enthusiast with PASSION for technology and making things work along with a knack for helping others understand how things work. He comes with around 20 years of solution engineering experience in application security, software continuous delivery, and SaaS platforms. He is known for his dynamic presentations in CI/CD and application security integrated in software delivery lifecycle.
Gopinath Rebala
Gopinath Rebala is the CTO of OpsMx, where he has overall responsibility for the machine learning and data processing architectures for Secure Software Delivery. Gopi also has a strong connection with our customers, leading design and architecture for strategic implementations. Gopi is a frequent speaker and well-known leader in continuous delivery and integrating security into software delivery.
Neuro-symbolic is not enough, we need neuro-*semantic*Frank van Harmelen
Neuro-symbolic (NeSy) AI is on the rise. However, simply machine learning on just any symbolic structure is not sufficient to really harvest the gains of NeSy. These will only be gained when the symbolic structures have an actual semantics. I give an operational definition of semantics as “predictable inference”.
All of this illustrated with link prediction over knowledge graphs, but the argument is general.
Kubernetes & AI - Beauty and the Beast !?! @KCD Istanbul 2024Tobias Schneck
As AI technology is pushing into IT I was wondering myself, as an “infrastructure container kubernetes guy”, how get this fancy AI technology get managed from an infrastructure operational view? Is it possible to apply our lovely cloud native principals as well? What benefit’s both technologies could bring to each other?
Let me take this questions and provide you a short journey through existing deployment models and use cases for AI software. On practical examples, we discuss what cloud/on-premise strategy we may need for applying it to our own infrastructure to get it to work from an enterprise perspective. I want to give an overview about infrastructure requirements and technologies, what could be beneficial or limiting your AI use cases in an enterprise environment. An interactive Demo will give you some insides, what approaches I got already working for real.
Software Delivery At the Speed of AI: Inflectra Invests In AI-Powered QualityInflectra
In this insightful webinar, Inflectra explores how artificial intelligence (AI) is transforming software development and testing. Discover how AI-powered tools are revolutionizing every stage of the software development lifecycle (SDLC), from design and prototyping to testing, deployment, and monitoring.
Learn about:
• The Future of Testing: How AI is shifting testing towards verification, analysis, and higher-level skills, while reducing repetitive tasks.
• Test Automation: How AI-powered test case generation, optimization, and self-healing tests are making testing more efficient and effective.
• Visual Testing: Explore the emerging capabilities of AI in visual testing and how it's set to revolutionize UI verification.
• Inflectra's AI Solutions: See demonstrations of Inflectra's cutting-edge AI tools like the ChatGPT plugin and Azure Open AI platform, designed to streamline your testing process.
Whether you're a developer, tester, or QA professional, this webinar will give you valuable insights into how AI is shaping the future of software delivery.
Software Delivery At the Speed of AI: Inflectra Invests In AI-Powered Quality
Money Laundering Paper
1. PROSECUTING THE ICT INDUSTRY:
MONEY LAUNDERING AND PROCEEDS OF CRIME
ACT (“POCA”)
1. Purpose of POCA.
Why bother the CSZ & ICT industry ?
2. Who/what are now targeted ?
Financial Institutions & DNFBPs - Duties of -STRs
3. What is prohibited ? Transactions & Wire Transfers
4. How ? Instrumentality
5. Penalties - Powers of NPA - Criminal + Civil liabilities
- Defences
6. Powers of Ministers + RBZ
7. What should CSZ do now ?
2.
3. FI ‗s + DNFBP‘s , called “dodgies”, are
subjected to AML/CFT regulation
because their services render them
vulnerable to abuse
by criminals for “dodgy transactions ”
enabling ML or TF purposes
4. ― FI ‖
―‖
means any
Section 2
person who conducts as a business
any of the following
for or on behalf of a customer—
(a)
acceptance of deposits and repayable funds from the public,
including private banking
(b) lending, consumer credit, mortgage credit, factoring ,f inancing of
commercial transactions
(c) financial leasing
(d) transfer of money or value
(e) managing means of payment, credit and debit cards, travellers‘
cheques, money orders , bankers‘ drafts, and electronic money;
(f) issuing financial guarantees and commitments;
5. g)Trading in
money market instruments
forex
money transfer agencies
bureaux de change.
interest rate and index instruments
transferable securities
commodity futures trading
participation in securities
7. Designated Non-Financial
Business or Professions
•
•
•
•
casino licensee, lottery licensees
―gaming operator‖
estate agent
precious stones dealer
precious metals dealer
•
any person engaged in mining or exportation of, or dealing in
•
Legal Practitioners
Chartered Secretaries
Public Accountants and Auditors
Chartered Accountants
Estate Administrators
platinum
8. who do :-
(j) safekeeping & administration
on behalf of other persons;
of cash or liquid securities
(k) investing, administering of money on behalf of other persons;
(l) underwriting ,placement of life insurance and other investmentrelated insurance,
(m) currency changing;
(n) the provision—
A. or cession of a life insurance policy or the
provision of reinsurance
B. of investment-related insurance services; or
C. of insurance underwriters or brokers;
9. WHAT IS MONEY LAUNDERING?
variously defined as the process of –
► concealing illicit gains from criminal activity;
► cleaning-up dirty money;
► taking the proceeds of criminal activity and making them appear
legal;
Criminals want their illegal funds laundered because they
can then move their money through society freely, without
fear that the funds will be traced to their criminal deeds.
laundering prevents the funds from being confiscated by the
police…
10. Sect 8
Money laundering offences
(1) Any person who converts or transfers property—
(a) knowing, believing or
crime; and
suspecting
that it is the proceeds of
(b) for the purpose of concealing or disguising the illicit origin of such
property, or of assisting any person who is involved in the commission of
a serious offence , to evade the legal consequences of his or her acts or
omission;
(2) ..who conceals or disguises the true nature, source, location,
disposition, movement or ownership of or rights with respect to
property, knowing or suspecting that such property is the
proceeds of crime…
(4) Participation in, association
with or conspiracy to commit,
an attempt to commit, and aiding, abetting, facilitating and
counselling the commission of any of the offences referred to in
subsections (1), (2) and (3)
commits an offence.
12. 9 Terrorist financing
offences
(1) Any person who by any means,
directly or indirectly,
provides or collects funds, or
attempts to do so, with the intention
that they should be used or in the
knowledge that they are to be used in
whole or in part—
(a) in order to carry out a terrorist
act; or
(b)
by a terrorist to facilitate
that person’s activities
related to terrorist acts or
membership in a terrorist
organization; or
(c) by a terrorist organisation;
commits an offence.
(3) It shall also be an offence
to—
(a)
participate
as
an
accomplice in an offence within the
meaning of subsection (1);
(2) An offence is committed—
(a)
even if the terrorist act
there referred to does not occur or is
not attempted; and
(b)
even if the funds
were not actually used to
commit or attempt the terrorist act
there referred to; and
(c)
regardless of
the State or territory in
which the terrorist act is intended or
does occur.
14. Since 1989
set 40
Recommendations
which all countries (whether
FATF members or not) are
expected to implement for
combating ML, TF and
Proliferation.
who are either members of the
FATF itself or members of
FSRBs.
180 countries
FSRBs are associate
members of the FATF.
include:
Eastern and Southern Africa
Anti-Money Laundering Group
(ESAAMLG)
of which Zimbabwe is a
member;
15. ― Grey List ― of 23 countries committed to the FATF
standard, but have not yet implemented it.
addressing AML/CFT deficiencies are….
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Algeria
Angola
Antigua and Barbuda
Argentina
Bangladesh
Brunei Darussalam
Cambodia
Kyrgyzstan
Mongolia
Morocco
11.
12.
13.
14.
15.
16.
17.
18.
19.
Namibia
Nepal
Nicaragua
Sudan
Tajikistan
Trinidad and Tobago
Turkmenistan
Venezuela
Zimbabwe
16. The role of
FIU established in 2004 within RBZ
receive STRs
from
“dodgies”,
analyze the data and pass on financial intelligence on
suspected ML, TF or other crime to law-enforcement agencies.
oversee AML/CFT compliance by
“dodgies”
and their reporting institutions’ supervisory
bodies.
coordinate formulation and implementation of AML/CFT policies at national level and act as the
national contact point for AML/CFT coordination and cooperation with relevant
external
organizations such as FATF, ESAAMLG and other FIUs.
under POCA “competent supervisory authorities” ie CSZ are required to co-operate with
the FIU to ensure compliance by the respective institutions or
and/or
levy
persons whom they regulate
supervise.
monetary
and
administrative
penalties
against
“dodgies” and their competent supervisory authorities
non-compliant
CSZ.
/
uncooperative
17. Financial Institutions & DNFBPs - Duties of –
PENALTY
us$ 700
or prison for 3 years
or both
Customer identification and verification requirements:
Sections 15-23
Cross- border correspondent relationships
- if unable to validate,
immediate report to FIU
Record-keeping requirements:
kept for 5 years after business relationship ended
Section 24
Putting in place internal programmes to combat ML and TF:
Section 25
(d) policies and procedures to prevent the misuse of technological
developments including those related to electronic means of
storing and transferring funds or value;
Compliance officer shall be designated at management level and
Requirements for ongoing due diligence & monitoring of special transactions:
Section 26
18. What is prohibited ? STR‘s red flags
for IT Agents Employees & Consultants of ―dodgies‖
Neither the FATF Standards, nor POCA define what a “suspicious transaction” is.
Examples of “red flag indicators” that should commonly raise suspicion of possible ML/TF include:► Moving funds to and from a “dodgy” employer’s Client account without any underlying legal
transaction backed up with instructions to/provision of services by the “dodgie’s”
o Eg funds being deposited into the “dodgie” client account, from which the funds are
subsequently transferred to 3rd parties, with no apparent underlying transaction/instruction.
► Unexplained aborted transactions / instructions
o IT should be wary of clients who, after depositing funds with the “dodgie” for a specified
purpose, make an unexplained u-turn and ask the funds to be paid back to the client or 3rd
parties, without rational explanation for the u-turn.
o In such cases, the “client” simply used their “dodgie” client account to place dirty money in the
financial system and clean it up.
Cash purchases of high value assets e.g. real estate, in circumstances where the amount of
funds is inconsistent with the client’s known or apparent legitimate sources of income.
In Zimbabwe, where mortgage finance is difficult, cash purchases of immovable
property are common and, very often the legal practitioner, accountant and estate
agent involved never carry out client due diligence to ascertain who their client really is
and what the source of funds is.
They want their fees + their Commissions
19. Wire Transfers
Section 13
― any transaction exceeding us1000
carried out on behalf of an originator through a financial
institution
Section 15(c)
(including an institution that originates the wire transfer
and an intermediary institution that participates in
completion of the transfer)
by electronic means with a view to making an amount of
money available to a beneficiary person at another financial
institution.
20. OBLIGATIONS REGARDING
Wire Transfers
Verification of identity of originator;
Obtain or maintain the account number or unique reference
number of originator;
Verification of the originators address, place of birth and national
registration;
Include the above information in records and also in the
message accompany transfer.
??? ECOCASH
MPESA ???
?? ZIMSWITCH
?
HOMELINK
21. shell banks
Section 14
(1) No FI shall establish or maintain any anonymous account, or an account under
fictitious names.
(2) No shell bank may be established or permitted to operate in or through the territory of
Zimbabwe.
(3) No person shall enter into or continue business relations with a shell bank or a
respondent FI in a foreign country that permits any of its accounts to be used by a shell
bank
(4) No DNFBP shall effect or facilitate a transaction where any director, principal, officer,
partner, professional, agent or
―dpoppae‖ of the business or
profession knows or has reasonable grounds to suspect that a party to the transaction is
acting anonymously or under a name that is not his or her own, unless the dpoppae
concerned in the transaction is satisfied as to the true identity of the party and that there
are legitimate reasons for the party so to act.
employee
DNFBP
(5) Where a
has effected or facilitated a transaction in which a party is acting
anonymously or under a name that is not his or her own, the dpoppae concerned in
the transaction shall, on behalf of the business or profession of which he or she is the
dpoppae, record its reasons for doing so and shall keep the record for at least 5
years after the completion of the transaction.
by gross negligence—
imprisonment for 10 years, or both .
(6) Any person who intentionally or
22. Penalties - Powers of NPA Criminal
1. interdicts applicable for twelve (12) months unless renewed before expiry;
2. property seizure orders where there is likelihood of dissipation or alienation of
property;
3. confiscation orders after conviction,
or before conviction when accused absconds
or dies;
4. benefit recovery orders to recover to the State all proceeds of crime;
5. civil forfeiture order where the property is tainted/terrorist property or used as an
instrumentality for such purposes.
6. Property freezing orders to preserve tainted, terrorist property or property used as
an instrumentality for such purposes
7. Monitoring order for information where a defendant has carried out or is carrying out
suspicious transactions
8. Customer Information Order where information of a certain customer is required
from financial institution
9. Production order where information concerning nature, identity, ownership and location
and appurtenant documents will be required to enable transfer and conveyancing
Compensation order made against NPA by a court as compensation of defendant for
property previously under confiscation, property, benefit recovery order etc where it has been subsequently
proven that the defendant was not guilty in a criminal trial
23. Powers of Director of FIU
liabilities Sects 4(1),(6) (8) , and
Civil
5 and 6
may issue Directive(s) for the best administration of the objectives of
POCA, providing for civil penalties , upon application to High
Court/Administrative Court/other superior courts be confirmed, varied ,or set
aside. – directing :
certain individuals shall no longer be allowed to be employed entirely or in
certain institutions, professions or capacities;
revocation and cancellation of
the named individual or institution;
licenses ,registration, permits etc of
sanctions against errant individuals or persons.
Fine not exceeding US$ 5OO per day of default of compliance
how adequate / actionable /legal are the means of enforcement?
?
Declaration of Rights of the new
Zimbabwe Constitution
24. What should CSZ do now ?
IT is in control
Training Members and non-members
Creating awareness of global provisions of ML laws ,
or face designation by the Minister as a DNFPB
- like the Law Society already is
– claiming client privilege as a ―defence‖ for non
compliance with STR‘s
Applied globally - IF RBZ & FIU DO THEIR WORK
Therefor SELF –REGULATE ? To create good
e-government practices ?