Course Summary
Understanding how financial crime impacts your FinTech business is essential to improving and managing your risk management. Failure to recognize your regulatory obligations can affect your ability to create new customer-centric products and to scale at pace.
What you will learn:
• The basics of financial crime
• Financial crime key words and definitions
• The types of financial crime risks faced by FinTechs
• How compliance roles work together to reduce risk
• How to identify the specific risk management programs
• What an effective due diligence process looks like
• The process for identifying then reporting suspicious activity
You may be early in your compliance career; interested in a compliance related role at a FinTech; or looking to progress to the AML
Intermediate for FinTech certificate.
1. Getting started
Introduction
• Instructions
• Introductory case video
• What would you do
• Feedback
• Learning objectives
2. What is financial crime?
Types of financial crime
• What is financial crime?
• Money laundering
• AML (Case example)
• Terrorist financing
• CFT (Case example)
• Sanctions
• Sanctions (Case example)
• Fraud
• Fraud (Case example)
• Anti-bribery and corruption
• ABC (Case example)
• Tax avoidance vs tax evasion
• Tax avoidance vs tax evasion: Panama Papers (Case example)
Review
• Review questions
3. Risk from financial crime
What is risk?
• Types of risk: Regulatory, legal, financial, reputational
• International regulations and guidance
• Categories of risk: Customer, jurisdiction, product, channel
• Politically exposed person risk and red flags
• Beneficial ownership
• Ultimate beneficial ownership
• Shell company risk and red flags
• Customer risk and red flags
• Customer risk and red flags in FinTech
• Jurisdiction risk and red flags
• Jurisdiction risk and red flags in FinTech
• Product risk and red flags
• Product risk and red flags in FinTech
• Channel risk and red flags
• Risk to FinTech from outsourcing AML controls
Risks specific to your business
• FinTech industry overview
• FinTech risk and red flags
• Revolut (Case example)
• Paris terror attacks (Case example)
• PayPal sanctions violations (Case example)
• YouTrip (Case example)
• FIFA (Case example)
• Charitable organizations (Case example)
Risk-based approach
• Risk-based approach to business
• Controlling risk
• Residual risk equation
• Risk-rating by applying your institution’s policies and tools
Review
• Review questions
4. Compliance roles
Know your role in compliance
• Three lines of defense industry-specific
• Risk-based escalation
• Dual controls
• Independence of the second line
• Role of MLRO
• Audit as the third line of defense
Review
• Review questions
5. Risk management programs
Know Your Customer
• KYC is intended to manage risk
• N26 (Case example)
Transaction monitoring
• Transaction monitoring is intended to manage risk
• Transaction monitoring process
• Typical scenarios that would generate an alert
• Fake investment product (Case example)
Sanctions compliance
• Who imposes sanctions
• Internet search: Sanctions screening
• Transaction monitoring vs name screening
• AMEX Travel Related Services Company (Case example)
Review
• Review questions
6. Due diligence
Research process
• Investigative mindset
• Four research steps
• Levels of due diligence
• CDD for a natural person
• CDD for a legal person
Information sources
• Criteria for selecting standard customer research sources
• If you need more information
• Tipping off
Organizing what you learn
• How much research is reasonably enough?
• Following organization-specific policies and procedures
• Filter what customer information is relevant and important
• Data security and privacy
• Documenting your research
• Customer profile structure and format
Review
• Review questions
7. Actions
Your obligation
• Duty to report
• Suspicious activity escalation process
How your organization might act
• What is a SAR/STR?
• Who writes a SAR in your organization?
• Transaction monitoring and ongoing reviews
• Maintaining an account after unusual activity
• Refusing or terminating a customer
Review
• Review questions
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