Euromoney Learning Solutions

Risk Based Approach to AML & ctf

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About the course

Design and execute effective AML and CTF programmes with this course

Attend this intensive and highly practical 3-day training course and learn the best practice techniques to:

  • Design an effective Anti-Money Laundering Program to support your organization?s Compliance and regulatory obligations
  • Establish and strengthen controls to combat terrorist financing through financial institutions
  • Understand best practices and guidelines designed to detect, investigate, report, escalate and resolve red flags, money laundering, and terrorist financing issues
  • Understand money laundering and terrorist financing processes
  • Identify both common and uncommon red flags and questionable behaviour
  • Be aware of the dangers of money laundering to clients, your organization and yourself
  • Be well prepared to help prevent criminals from using your firm to launder money and facilitate terrorist financing

PLUS: Gain appropriate knowledge and learn definitive risk management strategies through simulation exercises, class lecture, and group work to design and execute effective Anti-Money Laundering and Anti-Terrorist Financing Programs and Policies


Day 1

Setting the Stage: Anti-Money Laundering and Combatting Terrorist Financing Basics

  • Current international cases, fines, and legal judgments
  • AML/CTF success stories
  • Corporate and economic implications of AML/CTF
  • Key terms, definitions, and institutional differences
  • Legal and regulatory background to AML/CTF

The Money Laundering Process

  • Placement, layering, and integration
  • Red flags: unique to each business line
  • Relationship to terrorist financing and blocked assets
  • Roles: who’s responsible for what?

Terrorist Financing Operations

  • Funds generation
  • Transactions
  • Legal and illegal means
  • Relationship to money laundering

Case Study and Simulation Exercise 1: Delegates will, through review of a case, be assigned roles (customers, business line, middle and back office, compliance and legal, regulators) to analyze transaction data for possible money laundering activity/terrorist financing, escalation, reporting, investigating, and resolution)

Where It All Starts: The AML and CFT Rubric: Establishment

The Anti-Money Laundering and CFT Program

Design of an AML/CTF Policy

Effective Elements of the AML/CTF Program Policy

Identifying the Effective Elements

  • Designation of an AML and CTF Compliance Officer (s)
  • Auditing for AML and CTF: internal and external
  • Ongoing training
  • Due diligence and customer identification
  • Scenario, control, and systems testing
  • Supervision
  • Reporting and information flow: suspicious activity reports
  • Surveillance, systems, and investigations
  • Staffing, credentials, experience, and characteristics
  • Escalation
  • Record keeping

Day 2

Combating Terrorist Financing

CTF Goal: to aggressively identify, escalate and deter terrorist organizations’ funding and transactions networks

FATF Recommendations

FATF Global Money Laundering and Terrorist Financing Threat Assessment (GTA)

Risk Assessment Methodologies

FATF: Inclusion vs Exclusion

CTF Resources

  • Intelligence analysis
  • Sanctions administration
  • Enforcement
  • Financial regulatory action
  • Policy expertise

Implementation and Application of the Rubric

Policies, Procedures, and Controls: Implementation

  • Designation of an AML Compliance Officer
  • Auditing for AML: internal and external
  • Ongoing training
  • Due diligence
  • Customer identification
  • Supervision
  • Reporting and information flow: suspicious activity reports
  • Surveillance, systems, and investigations
  • Staffing, credentials, experience, and characteristics
  • Escalation
  • Record keeping

Risk Based Approach

  • Geography and country risk
  • Business risk
  • Product risk
  • Reputational risk
  • Transaction risk
  • Client risk
  • Process risk

Suspicious Activity Reporting

  • Trigger areas
  • Information flows
  • Preventing terrorist financing through AML

Case Study and Simulation Exercise 2: Response to Regulatory Review and Implementation of Follow Up Measures. Delegates will simulate A) regulator’concluding a review of a faulty AML Programme at a mid-sized financial institution and B) the financial institution’s response to the AML review and sanctions

Danger Zones: Failures

  • AML/CTF compliance policy
  • Faulty testing
  • Unsatisfactory training and non-compliance with training requirements
  • Insufficient resources: systems, technology, and staff
  • Lack of follow up: connect the dots

Organizational Settings

  • Laws, rules and regulations
  • International organizations
  • Information sharing
  • Industry organizations

Forensic Review of Surveillance and Investigation

  • Dissecting an AML/CTF Investigation
  • A day in the life of an AML/CTF surveillance team
  • Identification of red flags
  • Business line specific AML/CTF issues
  • Technology and AML/CTF: technology-based schemes, and technology-based monitoring, surveillance, and detection

Day 3

Know Your Customer Best Practices

  • Policy statement
  • Rationale
  • Customer identification programme
  • Application of the customer identification programme
  • Covered customers
  • Data collection: individuals, institutions, official/governmental organizations
  • Verification: documentary vs non-documentary
  • Logical consistency
  • Additional measures
  • Lack of verification
  • Data from external financial institutions
  • Service providers
  • High risk accounts

Special Topics

  • Shell banks
  • Politically exposed persons
  • Correspondent banks and foreign banking relationships
  • Enhanced due diligence
  • Identity theft
  • Charitable organizations
  • Volume

Monitoring Customer Relationships

  • Consistency
  • Pattern analysis
  • Systems
  • Aggregation
  • College knowledge vs flagrant indifference
  • Risk rating
  • Monitoring credit relationships

AML/CTF IN Practice: Implications for Business Lines

  • Internet gambling
  • Insurance fraud
  • Tax evasion
  • Wire transfers
  • Check collection
  • Funds transfer and money transmittal
  • Card dystems
  • Currency and monetary systems

Class Exercise and Simulation 3: Development of an AML Program Policy

Round Robin: AML/CTF and Sanctions Regulation Development

Course summary and close

Who should attend

  • Middle and Back Office Personnel
  • Front Office Sales Personnel
  • Compliance, Risk, Governance Officers
  • Regulators
  • Career Switchers into Compliance
  • Administrative Officers
  • Supervisors
  • System developers
  • Risk managers
  • Reporting specialists

The course assumes a general familiarity with financial markets, instruments and financial services.

Trust the experts

Mario Difiore

The course director is Assistant Dean, Senior Advisor and Adjunct Professor, Gabelli School of Business, Fordham University, New York (Former Co-Global Head and Director of Compliance Training, Deutsche Bank AG, Commercial and Investment Bank) He joined Fordham’s GSB Administration, July 2010 aft...


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