Anti-Financial Crime and Compliance

IFF Training

IFF Training


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About the course

This course is designed to provide a focused overview of the current key areas of financial crime, methods of prevention and detection as well as a good knowledge of the legal and regulatory environment under which organisations must operate in the UK.

This three day course is designed to provide a comprehensive guide to the key issues, legislation and implications. You will obtain a sound practical understanding of:

  • Global best practices in fraud detection and prevention; anti-money laundering processes and regulation as well as anti-bribery regulation
  • How to set up control systems and detect breaches
  • How to navigate through the relevant legislation and case law as well as indicating where new legislation is expected
  • How criminal activity has been detected and assets recovered – via real-life case studies and examples
  • The role of regulators and the consequences of not complying with regulations and the law

How You Will Learn

Get fully updated on the latest trends and methods of prevention and detection. Filled with the latest developments, both regulatory and otherwise

Including the Fraud Act, the Bribery Act, The Money Laundering Legislation, The Proceeds of Crime Act, The Criminal Finances Act 2017 and the changes due under the EU 4th Directive

Agenda Summary


Developing a Fraud Risk Analysis for your Organisation

  • Mapping your systems for fraud risks
  • Mapping for control points
  • Looking for compensating controls
  • Creating employee risk profiles
  • Documenting your Fraud risk analysis
  • Reviewing the ACFE system

Evaluating your Risks and Assigning Controls

  • Division of responsibilities
  • Reconciliations
  • Control accounts
  • Difference accounts
  • Authorisation levels
  • Film of GE Capital Fraud and control failures

Fraud Typologies in Banking, Commerce and Industrial Environments

  • Employee frauds – the facts
  • Payroll frauds
  • Computer frauds such as ransomware
  • Identity theft – Film
  • Current fraud risk areas

Financial Statement Fraud - Review of the Major Examples

  • Olympus Corporation
  • Diageo plc
  • Satyam Computer Services
  • Syntax-Brillian
  • Reebok India
  • Dell
  • Diebold
  • Rino International
  • WorldCom

EXERCISE An examination of a set of accounts where attendees will highlight areas of risk for investigation for potential fraud and identify the red flags

Detection of Fraud

  • Red flags
  • Fraud detection software


Actions to Take After Detection

  • Interviewing a suspected employee fraudster
  • Protecting a computer environment
  • Securing data for court purposes
  • Email analysis
  • Software for mapping links

The Fraud Act

  • Why was it necessary to create a Fraud Act
  • Passive and Active fraud
  • Potential developments in anti-fraud legislation
  • Comparison with the Bribery Act approach

FCA Financial Crime Reporting (Rep-Crim)

  • Politically Exposed Persons
  • Sanction listed countries
  • High risk jurisdictions
  • When to report a refusal of a customer on the basis of crime risk
  • SAR’s

Tax Evasion

  • Reporting to HMRC
  • Failure to prevent facilitation of tax evasion
  • Criminal Finances Act 2017


Fraud red flags


The Bribery Act 2010

  • The key provisions
  • Criminal offences for company’s and employees
  • Extraterritorial reach
  • The primary defence incorporated in the Act

The Bribery Act Offences

  • Active offence
  • Passive offence
  • Failure to provide training
  • Failure to assess risks
  • Failure to document assessments and controls

The Foreign Corrupt Practices Act and how it Differs from the Bribery Act

  • The limitations of FCPA
  • Private to private bribery restrictions
  • Limited to Active bribery only
  • No strict failure to prevent provision
  • Need to demonstrate intent
  • Facilitation payments allowed

DOJ Guidance and how it Should be Applied

  • What the guidance is
  • How a court will use the guidance
  • Has the guidance been modified since being issued

On-going Compliance and Obligations of the Act

  • Training – face to face
  • Training – e-learning
  • Risk based assessments
  • Checklists
  • Documenting assessments

Evaluating High Risk Areas of your Business

  • Sales agents commission
  • Cash transaction
  • Credit notes
  • Discounts and Rebates
  • Entertainment
  • Political donations
  • Customs duties
  • Employment

High Risk Circumstances

  • Joint Ventures
  • Acquisitions
  • Re-structuring
  • Legal disputes

Using your Contractual Documents to Impose your own Anti-bribery Policies

  • Reducing costs of ABC controls
  • How do you handle customers/suppliers who refuse to adopt your policies
  • Publishing your policies on the company website

Corruption and Corruption Indicators

  • Transparency International
  • What this index means and does not mean?
  • Are there other useful indexes?

Bribery & Corruption Risk Analysis

  • What is a risk based review?
  • Tone at the top
  • How do I set up a team for the review
  • Review questionnaires
  • Documentation
  • Reports - to whom and when

Practical Business Safeguards

  • Company policies
  • Intranet
  • An emphasis on regular training
  • Whistleblowing
  • High level reporting – compliance board

EXERCISE Creating your own risk scoring system for bribery utilising real loan applications


Why Money Laundering is at the Heart of Financial Crime – Money Laundering in the UK

  • The banking sector
  • Financial services
  • Gambling
  • Estate Agents
  • Jewellery, gold and other precious metals
  • Money Exchange Bureaus
  • Accountancy service providers
  • Lawyers

The Non-Regulated Sector

  • Those that can be regulated or non-regulated depending on circumstances
  • General insurers
  • Energy suppliers
  • Shipping

The Money Laundering Legislation 2007

  • These regulations operate alongside certain other Acts
  • The Proceeds of Crime Act 2002
  • The Terrorism Act 2000
  • The Terrorism Act 2006
  • What the ACT means (concisely)

The Proceeds of Crime Act 2002 Amended 2013

  • The purpose of POCA
  • How the Act works
  • What is the impact on the victim of crime?

The Changes due under the EU 4th Directive Effective from 4th June 2017

  • Emphasis on ultimate beneficial ownership and enhanced customer due diligence (CDD)
  • Expanded definition of a politically exposed person (PEP)
  • Expanded to included entire gambling sector beyond just casinos
  • Cash payment threshold lowered to €10,000
  • Enhanced risk-based approach, requiring evidence-based measures

Impact of the Changes in the UK due to be Announced in June 2017

  • Consultation completed in March 2017
  • Typically the UK is stricter than Europe and substantially stricter than the USA

The FCA and Other Regulators

  • Financial Conduct Authority
  • Gambling Commission
  • HMRC regulation of Estate Agents, Jewellers and Auction Houses


  • The creation and role of FATF
  • The standing of FATF reports
  • Why FATF has been so important in progressing AML practice

Terrorist Financing

  • FATF reports
  • Traditional methods of raising funds
  • Traditional methods of distributing funds
  • Lone actors and terrorist cells
  • Emerging threats

JMLSG Guidance

  • Who are the JMLSG
  • What is their purpose
  • Representation of Trade Associations
  • Reports on proposed legislation

Customer Due Diligence

  • Proving identity
  • Software products for high volume due diligence
  • Beneficial ownership
  • PEP’s
  • High risk jurisdictions
  • Sanctions

Transaction Monitoring

  • Stone vs. Natwest Bank
  • Automated monitoring
  • What is an unusual transaction?
  • Unusual intensity of transactions
  • Unusual destination of transactions
  • Higher than normal value transactions etc

Suspicious Activity Reports

  • What is a SAR
  • Who submits a SAR
  • When can you continue with a transaction
  • Shah vs. HSBC

The Risk Based Approach

  • Using computer software
  • FATF’s risk based approach
  • Risk assessment
  • Risk mitigation
  • Internal controls

Awareness & Training

  • The fundamental importance of training
  • Methods of ensuring AML awareness
  • Annual employment reviews

The MLRO and Reporting

  • The status and importance of the MLRO
  • How and when the MLRO reports
  • Once a report is submitted what happens next
  • Reporting and private clients

Record Keeping

  • How long should records be kept?
  • Why is it important to keep records?
  • In what form should the records be held
  • Disaster recovery

Criminal Finances Act 2017

  • Corporate offence of failure to prevent the facilitation of tax evasion
  • Unexplained wealth orders
  • Disclosure orders for money laundering investigations
  • Information sharing and “super SAR’s”
  • Extension of POCA powers to FCA and HMRC

EXERCISE Customer due diligence


Monica Bond

Monica is a Category A practising Solicitor, Chartered Accountant and Member of the Chartered Institute of Securities and Investment, with over 30 years’ experience in international banking transactions. She was in-house Counsel with S.G.Warburg & Co. (now part of UBS) and was subsequently H...

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Anti-Financial Crime and Compliance at IFF Training

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Coursalytics is an independent platform to find, compare, and book executive courses. Coursalytics is not endorsed by, sponsored by, or otherwise affiliated with any business school or university.

Full disclaimer.

Read more about Finance

During Finance courses, you will get acquainted with a huge number of financial analyst tools and learn how to work with them. So, you will learn how to make and analyze financial reporting, calculate the main financial indicators of the company and ...

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