Anti-Financial Crime Compliance & Risk Management
Learn the essentials of Financial Crime compliance and their importance for all risk departments
This three day training programme has been developed for professionals working in the financial services industry globally and covers:
- What is Anti-Financial Crime (AFC) compliance?
- The programme will review financial crimes including bribery and corruption, cybercrime, fraud, market abuse, money laundering, sanctions, terrorist financing, and weapons proliferation
- Review of the international AFC compliance regime for financial services firms
- Responsibilities of regulators, firms, senior management and staff
- Should firms be doing more to combat financial crime?
- What is your firm’s AFC strategy?
- What are the financial crime risks in achieving your firm’s commercial ambitions?
- Role and responsibilities of the AFC Compliance Function
- Being an AFC Compliance Officer/Money Laundering Reporting Officer (MLRO)
- Working with senior management, business lines, control functions, and regulators
- Risk identification, measurement, assessment and management
- Are you complying?
- Maintaining policies and procedures, systems and controls: best practices
- The importance of keeping good records
- Customer due diligence – do you really know your client?
- Suspicion reporting – what should you report? – when should you be suspicious?
- Are human beings your weakest link? Delivering effective training and awareness
- Challenges of investigations, enforcement and litigation
- Programme will include many casestudies reviewing lessons to be learnt from enforcement actions, and many typologies.
- Provide advanced training on AFC compliance requirements
- Increase awareness and understanding of risk-based AFC compliance best practices
- Provide practical tools for AFC compliance.
09.30 – What is AFC Compliance?
Bernie Madoff Casestudy: lessons to be learnt for financial institutions
- Why is it important for financial institutions to combat financial crime?
- Should firms be doing more?
- Internal and external threats: bribery and corruption, cybercrime, fraud, market abuse, money laundering, sanctions, terrorist financing, and weapons proliferation
- What does achieving effective compliance look like?
- Can you ever be sure your firm is and will remain compliant?
- Who is primarily responsible for the firm’s compliance?
- The role and responsibilities of senior management and AFC Compliance
- Compliance’s independence from the business lines
- Revenue generation: does good compliance mean good business?
- The Three Lines of Defence: the role and responsibilities of Compliance
- Risk assessment, advice, guidance, education, monitoring, testing and reporting
- Maintaining policies and procedures, systems and controls
- Working with Financial Intelligence Units and law enforcement
- Protecting your firm’s reputation in an age of financial turbulence
- Is compliance an integral part of your firm’s business activities?
- Does your firm have a compliance culture?
- Are we winning the war against financial crime?
10.30 Bribery and Corruption Essentials
11.00 – Morning Coffee
11.30 – AFC Compliance: The International Regime
- Financial institutions – in the front line of the war on financial crime
- Assessing risks and applying a risk-based approach
- United Nations – Conventions and Resolutions
- Basle Committee – Core Principles Effective Banking Supervision
- Basle – abuse of financial services, supervisory powers, responsibilities and functions
- Focus upon robust corporate governance
- Your firm’s strategy, organisational structure, control environment and compensation
- Managing risk – does your firm have a comprehensive risk management process?
- Basle Committee – Compliance and the Compliance Function in Banks
- Responsibilities of the Board and senior management for compliance
- Compliance should be independent and work with the business
- Compliance function responsibilities: do you have sufficient resources?
- The Financial Action Task Force (FATF), recommendations and current initiatives
- International Standards on Combating Money Laundering and the Financing of Terrorism
- Egmont Group of Financial Intelligence Units
- National AFC regimes: civil, criminal and regulatory liabilities
- Transnational business: the challenges for national regulators and law enforcement.
12.30 – Cybercrime Essentials
13.00 – Lunch
14.00 – Responsibilities of Regulators, Firms, Senior Management and Staff
- The nature of regulation beyond the financial crisis
- Authorisation, ongoing supervision and enforcement
- Firm to take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems
- How robust is your firm’s control environment?
- The responsibilities of the Board and senior management
- What is your firm’s strategy and risk appetite?
- Corporate structure, resourcing, internal organisation, reporting lines and job descriptions
- Who is responsible for what? Individual responsibilities and accountability
- AFC Compliance policies and procedures
- Do you have appropriate systems and controls to combat financial crime?
- “The Tone from the Top” – maintaining a compliance culture.
Systems and Controls Casestudy: review of the lessons to be learnt from a regulatory enforcement action about a Senior Manager’s “reasonable steps” responsibilities
15.00 – Money Laundering Essentials
15.30 – Afternoon Tea
16.00 – Being an AFC Compliance Officer/MLRO: Your Role and Responsibilities
- What are the attributes of an effective AFC Compliance Officer and MLRO?
- Qualifications, experience and personal qualities
- Recognising the challenges and personal demands of your role
- Working with management, business lines, control functions, regulators, law enforcement
- Understanding your firm’s businesses and their strategies
- To whom are you accountable? Stature, authority and independence
- Technical compliance expertise and the exercise of judgement
- Reporting obligations: to whom and what to report?
- Cross-border compliance: achieving consistency across all the business lines everywhere
- Overseeing the operation of a risk based approach and the implementation of policies and procedures, systems and controls
- Managing a compliance function and its staff
- Internal and external communications
- Achieving compliance in the age of the auditor
- How good are you at dealing with trouble?
Casestudy: review of regulatory enforcement actions against Compliance Officers
17.00 – Close
09.30 – Risk Identification, Measurement and Assessment
- Basle Principles – does your firm have a comprehensive risk management process?
- FATF Recommendations – assessing risks and applying a risk-based approach
- Is the risk-based approach working or is it a new form of tick box compliance?
- What is your firm’s business strategy and risk appetite?
- What are the compliance risks in achieving your firm’s commercial ambitions?
- Reputational risk: should we really be doing this business?
- Conducting an effective and auditable risk assessment
- Are your risk assessment and management processes tailored to the needs of your firm?
- Assessing risk in a changing environment: new products and business models
- What are the regulatory rules and expectations?
- What are your “Key Risk Indicators”?
- Working with and briefing Senior Management on the results of your risk assessment
- How effective are your risk management processes?
- Does the firm have a robust risk management culture?
- How can you best mitigate your risks?
- Producing a risk-based compliance programme.
10.30 – Terrorist Financing Essentials
11.00 Morning Coffee
11.30 – Are You Complying?
- Are your risk mitigators clearly linked to the findings of your risk assessment?
- Does the firm maintain a properly controlled operating environment?
- Implementing and maintaining policies and procedures, systems and controls
- Are they properly documented, regularly reviewed and updated?
- Are they effective? How do you find out if something, somewhere has gone wrong?
- Are good records being kept?
- Testing the controls: internal and external audit
- Monitoring, testing and reporting: staff, customers and transactions
- Are unusual activities being identified and escalated?
- Are you providing/receiving high quality MI or vanity metrics?
- Once identified, are problems addressed in good time?
- Does Compliance have enough resources and access to all information?
- Controlling and influencing staff behaviours: fostering awareness and understanding.
12.30 – Sanctions & Weapons Proliferation Essentials
13.00 – Lunch
14.00 Casestudy: review of the lessons to be learnt from recent regulatory enforcement actions relating to cross-border “Mirror Trades” * Do You Really Know Your Customer? * The customer relationship – the firm’s evolving responsibilities and liabilities * FATF Recommendations * Customer due diligence, transparency and beneficial ownership * New customer onboarding procedures * Who is the beneficial owner? Who is controlling your customer and its assets? * What is the purpose of the relationship? * Low risk customers and simplified due diligence * High risk customers and enhanced due diligence * Which customers are higher risk? * How can you check if you are dealing with a Politically Exposed Person? * Recognising that a low risk can become a higher risk * How do you verify the identity of individuals, companies, trusts and other customers?
15.30 – Afternoon Tea
16.00 – AFC Suspicion Reporting
- What must you report?
- When should you be suspicious?
- Do you have reasonable grounds to suspect?
- When must you report your suspicion? And to whom? What are the red flags?
- Typologies: cyrptocurrencies – correspondent banking – terrorism – trade finance
- Escalating findings from monitoring and surveillance
- Internal and external reporting procedures
- The offences of “tipping off” and prejudicing an investigation
- Working with the national Financial Intelligence Units.
17.00 – Close
09.30 Casestudy: review of lessons to be learnt from regulatory enforcement actions relating to AFC procedures Investigations, Enforcement and Litigation
- When and what do you need to tell your regulators and law enforcement?
- What are their powers and your responsibilities?
- Avoiding pitfalls in conducting an internal investigation
- Your governance: who is managing the investigation?
- What happened? Who was involved?
- Have you gathered all the evidence? Documentation, emails and interviews
- Who needs to take legal advice?
- Enforcement proceedings and litigation: the impact upon your business.
10.30 – Fraud Essentials
11.00 – Morning Coffee
11.30 Misuse of Information Essentials
- What are Confidential Information and Inside Information?
- When is and how long does information remain confidential?
- Need to know: managing information flows internally and externally
- Market sounding procedures
- Managing conflicts of interest and maintaining effective Chinese Walls
- Staff personal account dealing
- The dangers of emails and instant communication
- Data protection.
False and Misleading Statements and Practices Essentials
- What are proper standards of market conduct?
- What are your responsibilities to the market?
- Would you approve a transaction when the Front Office pushes the rules to the limit?
- Market abuse – manipulation, front running, cornering, short selling and beyond
- Protecting your firm against a rogue trader: unauthorised trading, position limit breaches
- Advertising and promoting your business.
Casestudy: review of lessons to be learnt from market conduct enforcement actions
13.00 – Lunch
14.00 – Are Human Beings Your Weakest Link? * Creating and maintaining a compliance culture * Senior Management and the “Tone from the Top” * Communicating a corporate culture and values to staff * Recruitment, terms of employment, compensation and discipline * The responsibilities of the line manager and staff supervision * Whistleblowing procedures.
15.00 – Is Your Staff Training Any Good?
- Do staff understand their regulatory obligations?
- Are they aware of the risks in your business?
- Are staff being regularly trained?
- Conducting a risk-based training needs analysis
- Maintaining induction and business line training programmes
- Are you delivering engaging training tailored to the business line?
- Train the trainer
- Do you run enough classroom training?
- The importance of keeping good records
- Can you show that your training is effective?
16.00 – Close