Anti-Financial Crime Bootcamp

This is an introduction into the world of crime and financial crime. We look at

1.What is Crime?

2.The cost of financial crime

3.Modern slavery and human trafficking

4.How human trafficking is used to commit crimes like pig butchering

5.We present our first case study that brings it all together

1.We look at why criminals need to launder money

2.We explain what is a predicate crime

3.We explore money laundering and anti-money laundering

1.We look at the different tricks of the money laundering trade

2.Money launderers use several ways to launder money and we look some of the common techniques

3.Case study.

We explain what terrorism and proliferation financing is, trade craft used to fund terrorism and the difference between money laundering and terrorism financing.

This is an introduction into the complex world of all things sanctions. We look at

1.What are sanctions?

2.Sanctions tradecraft

3.Advanced sanctions tradecraft

The only practical way to fight financial crime is to take a risk based approach and developing a core understanding of and appreciation for the risk based approach is critical to develop an effective anti-financial crime program. We get into the details of what this means, look at real life examples to help you understand and appreciate the risk based approach.

1.We explore the concept of 'diffusion of responsibility'

2.We explore the question of who is responsible for Fighting Financial Crime?

3.We look at the various Inter-Governmental Agencies, Governments, Regulators, Law Enforcement, Courts, and Reporting Entities

4.We explain how AML regulations became a priority on the global political agenda

5. We explain the role of Financial Intelligence Units (FIUs).

We explain

1.Business Risk Assessment

2.The key pillars of Risk Rating

3.Client Risk Rating

4.Country Risk Assessment

5.Product Risk Assessment

6.Industry Risk Assessment

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1. We explain why a risk based approach is critical to achieve effectiveness in the fight against financial crime

2. We explore the risks of the Risk-Based approach

3.We explain the three lines of defence and their role in mitigating financial crime risk

4.Case study

1.We explore the controls businesses must implement to fight financial crime including client due diligence(CDD)

2.Enhanced Due Diligence (EDD) including the triggers that may trigger EDD

3.Ongoing Due Diligence.

This module is a deep dive on Client Due Diligence (CDD) and we will cover the process including document collection, purpose behind document collection, requirements for corporations and other entities. Document verification, periodic reviews and remediation.

1.Source of Funds

2.Source of Wealth

3.The difference between Source of Funds Vs Source of Wealth

4.An exercise to confirm your understanding of this critical topic.

Having robust controls in place to identify and mitigate PEP(Politically Exposed Persons) risks is critical so we start with the question of

1.Who is a PEP?

2.Exercise: Identifying PEPs

3.Categories​ of PEPs

4.PEP Retirement

1.Beneficial ownership. This is a complex topic and something that even seasoned due diligence professionals get wrong. We explore, what is beneficial ownership?

2.Types of control

3.We work through a case to show how to conduct a Beneficial Ownership drill down (Simple and Complex Structure)

4.We explain what significant Influence and control in organisations mean.

1.Trusts - What are trusts

2. Foundations

3.Dramatis Personae (Key Players in Trusts)

4.Identifying Ultimate Beneficial Owners (UBOs)

5.Sources of Wealth in Trusts

6.Types of Interest

7.Differences between Trusts and Foundations

8.CDD for Trusts & Foundations

9.Beneficial Ownership Rules

10.Practical Trust & Foundation CDD Issues.

Nothing trips up businesses like ongoing due diligence especially transaction monitoring and screening so we cover.

1.Transaction monitoring: We explore identifying typical transactional red flags

2.Transactional red flags for terrorism including insights

3.We then bring it all together by presenting a case study that demonstrates the power of transaction monitoring to save lives

4.Screening: We cover screening for Sanctions, PEPs, Adverse Media, and Payments

5.We explain fuzzy logic, the process and Adverse Media Screening.

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One of the most important goals of an effective anti-financial crime program is to detect and report suspicions. Although it is called by many names, a good suspicious activity report (SAR) can go a long way towards stopping criminals, saving lives and livelihoods. We explain

1.The process

2.What constitutes a good SAR

3.Legal obligations

4.The risk of tipping off

5.The regulatory expectations about tipping off.

The MLRO has ultimate accountability, authority and responsibility to ensure their business has an effective anti-financial crime program. We explain

1.The role of an MLRO

2.What happens when a suspicion is flagged and questions for an MLRO considers

3.We also look at the role of the Financial Intelligence Unit (FIU)

4.What happens when the FIU receive a SAR or SMR

We present a case study that brings it all together. This is a real life investigation that Ray was involved in and brings together everything you learn at the bootcamp and helps you connect the dots.