Financial Crime Compliance (FCC)

Advanced AML Loadicator

• What is “not” money laundering
• What “is” money laundering
• Offence 1: Concealment
• Offence 2 Arrangements
• Offence 3: Acquisition, use and possession
• SAR Narrative Review - internal reporting
• SAR lodging – external reporting

Advanced ABC Loadicator

• Tracing capital flight from developing countries
• Sustainable development goals in practice
• Illicit financial flows
• UNCAC and beneficial ownership transparency
• Beneficial ownership registries
• Scanning and profiling legal entities and complex legal arrangements

AML Tools

• Tool 1: KYA (Know Your Assets)
• Tool 2: KYB (Know Your Business)
• Tool 3: KYC (Know Your Customer)
• Tool 4: CDD (Customer Due Diligence)
• Tool 5: EDD (Enhanced Due Diligence)
• Tool 6: SDD (Simplified Due Diligence)

Business Unit and Customer Profiling

• Linking clients with transactions
• How to regularly assess ML and TF risks: sources
• Risk assessment and vulnerability of transactions
• Fitting your FCC programme in the “holistic” risk-based approach – whose?
• Evidenced-based decision making and targeting ML and TF risks faced by the host State and regional organisations
• Transparency: internal standards and controls
• SYSC: Single vs Several Operations – your suspicion matrix
• Data Protection for businesses and the rise of the Data Protection Officer

FCC Re-tooling

• Risk assessments – why? which? and where from?
• FATF, Basel AML Index and ESMA reloaded
• Risk-based approach
• Putting it all together in the SYSC context
• Trade-based ML – misinvoicing and third-party risk management
• Financial sanctions: EU, International, and U.S.
• Proliferation financing