Course Summary
FinTech businesses need to understand and be alert to where financial crime risks lie. Balancing fast-paced innovation, rapid growth, and customer experience – alongside regulatory requirements – is essential to being compliant.
You will learn how to:
• Meet your regulatory obligations
• Identify and mitigate different types of financial crime risks
• Maintain an efficient risk management program
• Conduct effective risk-based due diligence
• Tune and scale your transaction monitoring program
• Investigate suspicious activity and collaborate with law enforcement
To participate, you may be early in your compliance career; interested in a senior compliance related role at a FinTech; or looking to progress to our the:
Certified AML FinTech Compliance
Associate (CAFCA) certification.
1. Getting started
Introduction
• Instructions
• Introductory case video
• What would you do
• Feedback
• Learning objectives
2. Risk from financial crime
Regulation related to FinTech
• Levels of regulation for FinTech
• Registration and licensing for FinTech
• Industry perceptions of FinTech risk
• FinTech partner relationships
• De-risking of FinTech by partners
Risk-based approach
• Risk assessment methodologies in FinTech
• Risk assessment of novel FinTech products and channels
• Balancing risk appetite with customer growth
FinTech risk and red flags
• Categories of risk: Customer, jurisdiction, product, channel (Reminder)
• Customer risk and red flags (Reminder)
• Risks of key FinTech models and products
• Banking as a service models
• FinTech sizes and capabilities FinTech payment channels and risk
• FinTech payments channels
• Card schemes and red flags
• Fraud risk
• Handling chargebacks
Review
• Review questions
3. Risk management program
Know your role in compliance
• Three lines of defense in FinTech
• The role of the Board of Directors in FinTech
Customer Risk Assessment
• Customer risk assessment for FinTech
• Customer risk data points FinTech can collect
Maintaining an AML Program
• Maintaining AML policies and procedures
• AML ongoing training, awareness and resources
• Periodic testing and assurance in a FinTech
• Different types of audits and how to prepare
• Using AML controls to generate usable MI
Reducing Internal Risk
• Internal risk in a FinTech
• Internal risk control frameworks
• Recordkeeping requirements for FinTech
• Data security and privacy (Reminder)
• Intersection of cybersecurity and financial crime
Review
• Review questions
4. Transaction monitoring
Clearing alerts
• Transaction monitoring process (Reminder)
• Alert clearance for FinTech
• Risk-based approach to transaction monitoring
Ongoing Monitoring
• Monitoring for corporate money laundering
• Monitoring for terrorist financing
• Monitoring for organized crime
• Monitoring for sanctions evasion in FinTech
Maintaining a Monitoring Solution
• Anti-fraud vs AML monitoring solutions
• Science behind alert generation
• Artificial intelligence and machine learning
• Tuning
• Tuning in FinTech
• Scaling a transaction monitoring program –
what does change look like?
Review
• Review questions
5. Investigating suspicious activity
Communicating with Customers
• Balancing fairness to customers and AML obligations
• Customer experience and AML obligations
• Tipping off (Reminder)
Technology and Investigations
• Network analysis in AML investigations
• Applying technology to AML investigations
Best Practices in Investigation
• Criteria for selecting standard customer research sources (Reminder)
• Utility of open source research
• Evaluating bias in open source research
• Critical thinking in investigations
• Filter what customer information is relevant and important (Reminder)
Review
• Review questions
6. External relationships
Outsourced financial crime controls
• Working with RegTechs for AML
• Working with contractors and consultants for AML
Other financial institutions
• Indemnities and requests from financial institutions
• Partner institution relationships
Government
• Law enforcement enquiry types
• Law enforcement enquiry responses
• Communicating with regulators
Review
• Review questions
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