Introduction
PresentationA good KYC process must include three stages:Customer identification - the first part of the process is to ascertain the true identity of the customer and to ensure that all controls are proven;
Customer due diligence - the process of evaluating who the customer is, what activities they are engaged in and in which geographic areas they operate. Requests for due diligence can range from simple measures to higher levels of control for high-risk individuals, businesses or areas of operations.
Continuous Monitoring - It is important to maintain continuous monitoring of customers and any significant changes or variations in the business to be investigated.The course is designed to ensure that financial crime risk professionals acquire the necessary knowledge to efficiently and effectively manage the risks of money laundering, tax evasion and financial crime and terrorist financing within their organizations.
The course focuses on these issues and on specific aspects of governance and internal controls, identified by international and local regulatory bodies.
The course draws on the trainers' extensive experience in collaborating and delivering courses for a wide range of financial institutions.
As such, it will be both practical and interactive and should be of interest to compliance, finance and risk professionals from financial institutions and other relevant entities.AimsThe course aims to provide a systematic and comprehensive analysis of the legal and regulatory guidelines that companies must follow in managing the risks of money laundering, tax evasion and terrorist financing.
The course deals with best practices in governance, risk management and internal control of the aforementioned financial crime risks. It includes several case studies, exercises and talking points, and as such will be highly practical and interactive.
Participants will develop a greater appreciation and greater understanding of the KYC process:international legal and regulatory framework within which customer due diligence is required;
Incorporation of this framework into local laws and client risk management practices;
Specific high-risk threats and challenges to customers, products, geography and business;
Framework for the risk-based corporate assessment required for a holistic approach to managing the risks of money laundering, tax evasion and terrorist financing;
Importance of client due diligence in deterring, identifying and protecting against financial crime risks;
Importance of governance, internal control and culture in managing financial crime risks;
Continuous escalation and threat management procedures in financial crime risk management.StructureIn the DIGITAL LEARNING version, however, the course is structured in 8 modules corresponding to 8 half days.
For both training modalities it is possible to optionally add the e-learning activity and the Certification of Outgoing Skills with final written and oral exam.Program (extended)Module 1: First part
Opening exercise: You are the Money Launderer
Prerequisite crimes of money laundering and terrorist financing;
Scope and scope of financial crimes
Reputational risk
Regulatory and legal framework (notes):United Nations Security Council Resolutions
United Nations conventions
International Financial Action Group (FATF)
Egmont Group
EU directives
Wolfsberg Group
Joint Money Laundering Steering Group (JMLSG)
FinCEN & USA Patriot Act
OFAC (Office of Foreign Assets Control)Risk-based business assessments:Clients
Products and services
Geographical locations
Transactions
Delivery channels
Size, nature and complexity of the business
Case study: Standard Rented BankModule 1: Second partRisk mitigation and management
Strategic business
Governance
Organizational culture and the importance of the 3 lines of defense (3LOD)
Policies and procedures
Risk management
Internal controls
Specific products and services
Record keeping
Training
Communications
Reporting
Due Diligence for the clientExercise: Communicate the change in anti-money laundering policy
Customer Due Diligence (CDD)When is the CDD required?
The CDD process
Identification and verification (ID and V)
Screening
Individuals
Business owners and controllers
CompaniesModule 2: First part
Know your customer (KYC)Purpose of the report
Source of funding
Source of wealth
Nature of businessEnhanced Due Diligence (EDD)
Due diligence in progress
Risk approval framework
Client risk model and valuation
Simplified due diligence
Case study: Danske Bank Estonia
Specific guidelines for CDDs
Module 2: Second part
Remote customers and digital IDs
Trust and trust accounts
Group exercise: Is there a UBO?
Obligation to perform EDD
High risk of money laundering and terrorist financingCharities companies
Casino and gaming company
Military and Defense
State property
High-risk third country
PEP and PEP'sModule 3: First partRelations with correspondents
Transparency of payments
Trade finance transactions
Transactions with no apparent economic and legal purpose
New technologies: crypto currencies
Corporate scams by email
Non-financial activities and professions
Case study: Deutsche Bank Mirror Trades
Case study: Latvian banks
Case study: London's housing boomModule 3: Second part
Customer risk managementTransaction monitoring
Negative news screening
Escalation procedures
Unusual activity
Suspicious activity reports (SARs)
Reports on suspicious transactions and orders
Reputation risk management
WhistleblowingCase study: Sanctioning measures in Italy and Malta
Module 4: First partOSINT (Open Source INTelligence) techniques as an alternative to finding reliable data to support KYC
What is OSINT and why it is useful in KYC (Identification, Due Diligence, Monitoring)
Open Source Sources
Basic techniques for OSINT analyzes
Operator safety: Tor, VPN, profiles
Search engines: basic use, dorks, custom engines
Case study: Start up Zelp ltdModule 4: Second part
OSINT (Open Source INTelligence) techniques as an alternative to finding reliable data to support KYC
Search for information in Social NetworksFacebook
Instagram
Linkedin
TwitterThe Deep Web
Case study: OSINT analysis of one of the 10 richest football teams in the world.
