Course Summary
The course is delivered by subject matter experts working around the world. It pulls examples from many countries, and is globally appropriate.
The lessons and examples are relevant to any industry.
A primary focus in the course is “financial institutions,” including banks, credit unions, asset managers, insurance, MSB, securities broker-dealers, credit card issuers, alternate payment systems, etc.
In this Anti Money Laundering (AML) Foundations course, you will learn:
• How to define different types of financial crime.
• The different types of risk and what a risk-based approach means.
• How compliance roles work together to reduce risk.
• How to identify the specific risk management programs.
• The due diligence process and its related information sources.
• The process for identifying and reporting unusual and suspicious customer activity.
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 screening Amazon (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 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
• Customer risk and red flags
• Politically exposed person risk and red flags
• Beneficial ownership
• Ultimate beneficial ownership
• Shell company risk and red flags
• Cash-intensive business risk and red flags
• Jurisdiction risk and red flags
• Money Services Businesses and high-risk jurisdictions
• Product risk and red flags
• Life insurance product risk and red flags
• Channel risk and red flags
• Electronic transfer of funds risk and red flags
• Remote deposit capture risk and red flags
Risk-based approach
• Risk-based approach to business
• Controlling risk
• Residual risk equation
• Risk-rating by applying your institution’s policies and tools
4. Compliance roles / Know your role in compliance
• Three lines of defense
• Risk-based escalation
• Dual controls
• Independence of the second line
• Role of MLRO
• Audit as the third line of defense
• Review questions
5. Risk management programs / Know Your Customer
• KYC is intended to manage risk
• KYC Case example
• Transaction monitoring
• Transaction monitoring is intended to manage risk
• Transaction monitoring process
• Typical scenarios that would generate an alert
• Transaction monitoring Case example
• Sanctions compliance
• Who imposes sanctions
• Internet search: Sanctions screening
• Transaction monitoring vs name screening
• Consequences: regulatory, financial, reputational (Case example)
• 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 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
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