Category Archives: Banking sector

Fraud including Credit Card Fraud and Suspicious Transactions Course

Fraud including Credit Card Fraud and Suspicious Transactions Course

credit card fraud core categories of a risk based approach

Complete the form below to contact us!

What Makes Compliance Consultant Courses Different
  • We have been delivering training for over 20 years and this is one of our core competencies. We believe we are experts on this topic and having delivered training to a wide range of firms and businesses, we are certain we know the topic as well as anyone in the market place
  • Your course director is a highly successful and experienced executive who will pass on past experiences and “war stories” generally to enhance the workshop and help bring it to life
  • We do not use academics. All our trainers are highly experienced professionals with relevant vocational experience in the real world
  • We have delivered many fraud and financial crime courses over the last few years and have a very clear understanding of what may be contributing to the fraud. In addition, participant feedback informs us in both a precise and timely manner what the changing regulatory imperatives are over time.
  • We have developed highly interactive and very enjoyable case studies to enhance the learning points. All delegates report that these are a high point
  • We are always judged by our results which speak for themselves and the feedback received from previous delegates has always been excellent
Course Objectives
  • The aim of the Course is to provide fraud managers and others to obtain a wider understanding of risk management within the context of external fraud.
  • The delegates will have the ability to understand fraud risk in the wider context of enterprise risk management and business in general.
  • If you are responsible for drawing up financial policies as part of your job, this course will help you decide which checks/framework to put in place and how to enforce them
  • If you have been investigating or det4ecting fraud, this course may help you understand the perpetrator’s motives and the various factors that prompted their actions
  • This course will help you identify suspicious behaviour, which in turn will allow you to play your part in tackling this common crime.
  • This will include the ability to conduct a fraud risk assessment and manage the findings.
Course Content
Session 1
  • So You Have A Fraud Situation, Really?
  • What’s the difference between fraud and bribery/blackmail?
  • 11 Common Types of Credit Card fraud & crimes
  • 8 Types of identity theft and ways to spot them
  • Definitions, types of fraud, scale and typologies
Session 2
  • AML MLR 2017 S33, 37 & 38 – What Makes A Suspicious Transaction?
  • Difference between Suspicious Activity & Suspicious Transactions.
  • 19 Red Flags for AML/CTF
  • Where are Suspicious Transactions identified?
  • CDD & EDD Monitoring
  • The legal requirement to monitor Suspicious Transactions.
  • Suspicious transactions, involving;
  • Investment Fraud
  • Loan/Credit card application fraud
  • Other miscellaneous fraud
Session 3
  • The Modern Fraud Risk Management Framework
  • The drivers of financial crime, offending and the types of financial crime commonly encountered.
  • The international frameworks designed to help counter financial crime.
  • How will 2FA beat Card Fraud?
Session 4
  • The Fraud Triangle
  • The people problem: motives and behavioural issues behind fraud – the Fraud Triangle, who commits fraud and why
  • Role of directors and Responsibilities of senior managers for fraud prevention and detection.
  • The role and responsibilities of auditors in fraud prevention and detection.
Session 5
  • Workshop of scenarios (with PM break as appropriate)
  • 11 most common forms of credit card fraud.
  • Application Fraud
  • Electronic or Manual Credit Card Imprints
  • CNP (Card Not Present) Fraud
  • Counterfeit Card Fraud
  • Lost and Stolen Card Fraud
  • Card ID Theft
  • Mail Non-Receipt Card Fraud
  • Doctored Cards
  • Fake Cards
  • Account Takeover
  • Quiz: Are They A PEP or Not a PEP?
Session 6
  • Assumed Identity involving some or all of the following 8 types of identity theft;
  • Financial Identity Theft
  • Driver’s License Identity Theft
  • Criminal Identity Theft
  • Social Security/Gravestone Identity Theft
  • Medical Identity Theft
  • Insurance Identity Theft
  • Child Identity Theft
  • Synthetic Identity Theft.
Course Conclusion
Your Course Facilitator/Director Backstory
Your course director has spent over 30 years in the banking and financial sector, much of it in a Senior Managerial/Director role. A highly successful, long and varied “fast track” career in Banks led him to very senior management at an early age. Challenged by the industry reluctance to adopt regulated principles, he entered compliance 20 years ago and has run a successful consultancy ever since.

The trainer has been a freelance training consultant since 2000 and is an expert on FCA and regulatory compliance generally. As a Chartered FCSI he has also created and delivered training to a vast range of clients from global giants to small partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, Europe, Africa, and the Middle East.

He is a highly adaptive, hands-on and highly sought-after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience from “black belts” to novices. His expertise includes but is not limited to Regulatory Compliance, Risk Management, Trade Finance, FCC & AML and all aspects of Corporate, Private & Retail Banking.

Lee has written several books, available at Amazon including “The Compliance Managers Guide & Reference” and “Conduct Risk”.

He is also a highly experienced soft skills trainer and has completed numerous “train the trainer” assignments.

Online Courses you may be interested in

SMCR For Limited & Core Firms – Click on this link => http://bit.ly/SMCRcse

Digital Onboarding for Fintech Firms – Click on this link => http://bit.ly/DigitalCheck


Need a Compliance Manual? Our Top-selling Template is available HERE

Need an AML & CTF Policy and procedures template? Our Top-selling Template is available HEREaml template fca mlr2017


 

 

 

 

 

 

This Course Can Be Presented In The Following Formats:

 

Public Course

Future Dates Not Yet Available

 

Face to Face In-House

 

This course can be tailored and presented in-house at your location for 3 or more participants.

 

From £850

 

Live In-House Webinar

 

This course can be tailored and presented exclusively via live webinar for your company for a group of participants. Participants are given a link and login and the trainer presents the course to a maximum of 20 participants.

Participants can login from different offices.

From £850

 

Pre-Recorded In-House Webinar

 

The trainer records the course exclusively for your company – in one session or in “bite-size” video files. We provide access to our Proprietary Online System, the whole course as a pdf and any supporting course materials for an agreed amount of time (6 or 12 months) for any number of participants up to 5,000.

From £3,000

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SAR Workshop and Adverse Media Risk Assessments

Subject Access Reports Workshop and Adverse Media Risk Assessments for business and recruitment.

sar adverse social media risk based approach

Complete the form below to contact us!

What Makes Compliance Consultant Courses Different

  • Failure to file an appropriate SAR can lead to big trouble. But regulators also caution against filing unwarranted “defensive” SARs.

  •  Our experts provide practical advice for the high-wire balancing act of when, and when not, to file a SAR.

  • This includes decision-making methodologies that you can apply enterprise-wide; separating anomalies from red flags; and how to replace subjective judgment calls with clearly objective determinations.

  • Your course director is a highly successful and experienced executive who will pass on past experiences and “war stories” generally to enhance the workshop and help bring it to life

  • We do not use academics. All our trainers are highly experienced professionals with relevant vocational experience in the real world

  • We have delivered many AML and financial crime courses over the last few years and have a very clear understanding of what may be contributing to the fraud. In addition, participant feedback informs us in both a precise and timely manner what the changing regulatory imperatives are over time.

  • We are always judged by our results which speak for themselves and the feedback received from previous delegates has always been excellent.

  • It’s a can’t-miss tutorial on a lingering compliance conundrum.

Course Objectives

   
  •  Establishing review/risk committees to ensure consistent escalation practices

  •  Ensuring you know when and when not to make a Suspicious Activity Report

  •  What to include in a local SAR

  •  Rating suspicious activities to assure conformance to institutional standards like the The FATF 40 Guidelines

  • The categories and areas of concern under NLR 2017

  • Where Suspicious Activity is identified, and the Red Flags raised

  • What Social Media checking is available and why Search Engines are not enough

  • Where to find other sources of intelligence to help your decision making

Course Content

 

 

Session 1

   
  • Local SAR Reporting
  • MLRO’s Role in SAR Evaluation
  • FATF and the 40 Guidelines
  • MLRO completion of a SAR
  • When, and when not, to file a SAR.

Session 2

   
  • Difference between Suspicious Activity & Suspicious Transactions.
  • 5 Categories and 27 Areas of Concern under MLR2017
  • 10 Banking Areas that raise suspicions
  • 19 Red Flags for Property AML/CTF
  • Where are Suspicious Transactions identified?
  • CDD & EDD Monitoring – MLR 2017 S33, 37 & 38

Session 3

   
  • Adverse Social media – Facebook, Insta, Twitter etc
  • Other sources of adverse media/intelligence
  • 3 Areas of search for Adverse Media
  • 5 Best Practices for Adverse Media Checks

Session 4

   
  • 7 Best Tools For searching for social media accounts
  • Workshop – Suspicious Activity Scenarios

Course Conclusion

 

 

Your Course Facilitator/Director Backstory

   
Your course director has spent over 30 years in the banking and financial sector, much of it in a Senior Managerial/Director role. A highly successful, long and varied “fast track” career in Banks led him to very senior management at an early age. Challenged by the industry reluctance to adopt regulated principles, he entered compliance 20 years ago and has run a successful consultancy ever since.

The trainer has been a freelance training consultant since 2000 and is an expert on FCA and regulatory compliance generally. As a Chartered FCSI he has also created and delivered training to a vast range of clients from global giants to small partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, Europe, Africa, and the Middle East.

He is a highly adaptive, hands-on and highly sought-after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience from “black belts” to novices. His expertise includes but is not limited to Regulatory Compliance, Risk Management, Trade Finance, FCC & AML and all aspects of Corporate, Private & Retail Banking.

He has written several books, available at Amazon including “The Compliance Managers Guide & Reference” and “Conduct Risk”.

He is also a highly experienced soft skills trainer and has completed numerous “train the trainer” assignments.


Online Courses you may be interested in

SMCR For Limited & Core Firms – Click on this link => http://bit.ly/SMCRcse

Digital Onboarding for Fintech Firms – Click on this link => http://bit.ly/DigitalCheck


Need a Compliance Manual? Our Top-selling Template is available HERE

Need an AML & CTF Policy and procedures template? Our Top-selling Template is available HEREaml template fca mlr2017


 

 

 

 

 

 

 

 

 

 

 

This Course Can Be Presented In The Following Formats:

 

Public Course

Future Dates Not Yet Available

 

Face to Face In-House

 

This course can be tailored and presented in-house at your location for 3 or more participants.

 

From £850

 

Live In-House Webinar

 

This course can be tailored and presented exclusively via live webinar for your company for a group of participants. Participants are given a link and login and the trainer presents the course to a maximum of 20 participants.

Participants can login from different offices.

From £850

 

Pre-Recorded In-House Webinar

 

The trainer records the course exclusively for your company – in one session or in “bite-size” video files. We provide access to our Proprietary Online System, the whole course as a pdf and any supporting course materials for an agreed amount of time (6 or 12 months) for any number of participants up to 5,000.

From £3,000

Contact Form

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KYC and AML – Suitable for all firms with AML responsibilities

The UK is one of the world’s largest and most open economies, whose strength is based on substantial and productive relationships around the world. Government Ministers have the responsibility for national security and financial services, so they want the UK to remain to be an appealing country for legitimate business and a leading global financial centre. But they also recognise that the UK’s openness and position as a global financial centre exposes it to the risk of illicit financial flows.

Money laundering and terrorist financing are important threats. Recent terrorist attacks in London, Manchester and elsewhere highlight the value of the fight to deprive terrorists of the resources they need. Serious and organised crime has been estimated to cost the UK tens of billions of pounds yearly. That is why we must continue to squeeze out dirty money, strengthening the UK’s security and prosperity as well as that of our partners overseas.

What makes Our Course Different?

  • We have been delivering KYC training for over 12 years and are proud to have been chosen by some of the world’s leading banks.
  • Your course director is an expert on the subject, has over 30years’ experience in the industry and has delivered highly successful programmes to financial services firms at all levels; from small partnerships, to medium sized firms and global giants
  • The course is packed full of interesting points and actual case studies making it highly engaging and very relevant
  • Our feedback from past delegates has always been excellent

Objectivesaml template fca mlr2017

  • Understand fully the requirements of MLR2017
  • Understand that good enough, seldom is
  • Appreciate that this is mandatory, not optional
  • Recognise the importance of a risk assessment
  • Recognise the critical role of a risk based approach
  • Be able to put in place a framework meet the regulatory requirements fully
  • Recognise that AML is a holistic process and needs to be embedded into culture and form part of doing business as usual
  • Recognise and be able to deal with the challenges of implementing an effective system

Content

  • Introduction – What is Money Laundering
  • Placement, Layering, Integration
  • How does this work in practice
  • The scale of the problem

Establishing a KYC framework

  • What should instittions have in place
  • Money Laundering Regulations 2017
  • Changes
  • General risk assessment
  • Risk mitigation policies
  • Level of due diligence
  • Reliance on third parties
  • PEPs
  • New Criminal Offence
  • Office for Professional Body Anti-Money Laundering Supervision (OPBAS)

What is KYC & CDD

  • Initial Risk Assessmnet
  • Risk based approach & Methodology
  • Risk driven controls
  • Material triggers
  • The customer lifecycle

The CDD process smcr project plan regulation buy now how do

  • KYC – getting to know the customer
  • IDV – checking what they say
  • SDD? Is it really viable?
  • EDD – more comprehensive client knowlede and due diligence
  • Ultimate Beneficial Ownership
  • Source of Wealth
  • Source of Funds
  • Regular review process

Remediation process – introducing new rules and requirements for the first time

  • How  Should CDD or EDD be applied
  • Using a risk based approach onlyl
  • How do we allocate the risk category
  • A typical Risk Assessment Methodology
  • Using the RAM in practice
  • The three plus two lines of defence model

Who needs to be subjected to KYC?

  • Onboarding and Review procedures
  • Using technology – a must for large volumes
  • Swim lines
  • Expetion report and alerts
  • The role of the second line of defence
  • The role of internal audit

Essential Elements of KYC Standards

  • Clear and user friendly procedures and guidelines
  • Customer acceptance policy
  • Customer identification policy
  • Guidelines for opening accounts
  • KYC for existing accounts – called “remediation” and needs to be managed well

Politically Exposed Persons

  • Definition – formal
  • Definition in practice
  • Why are they a special case
  • Mandatory high risk
  • UBO issues
  • Source of Wealth issues
  • Annual Review issues

Specific Identification & Verification Issues

  • Trust nominee and fiduciary accounts
  • Corporate vehicles
  • Complex Structures
  • Introduced business
  • Client accounts opened by professional intermediaries
  • Non face to face customers
  • Offshore accounts

Constructing the KYC Framework

  • Policies
  • Roles and Responsibilities
  • Senior Management and M.I. requirements
  • The MLRO (or equivalent) challenge!
  • Risk Assessments and Procedures

Implementing and Managing the Total KYC

  • Escalation
  • SAR’s & Whistleblowing
  • Due diligence (on-going)
  • Record keeping
  • Training
  • Monitoring
  • Reporting

Challenges with KYC & How To Control It

  • Staff & Client resistance
  • Embedding as part of the culture
  • Prevention & detection
  • Early warning systems
  • Controls, KPI & KRI

Course Summary, Open Forum, Close

Background of the Trainer

Course Director

Lee has worked with a range of organisations from smal start-ups through to FTSE100 companies, including foreign banks and institutions, many that have had difficulties identifying and managing compliance risk, and helped them develop effective, robust systems. He has adapted his experience to develop this course and supporting materials with the practical skills based focus. Lee’s skills, qualifications and experience make him ideal for supporting anyone wishing to develop top-class knowledge in the management of Anti-Money Laundering and Counter Terrorist Financing.

Course Summary

This is a highly interactive, user friendly and comprehensive workshop for both banks and other regulated institutions and practitioners alike. It covers the KYC procedures and systems that all regulated institutions must have in place and deals with the full range of clients from straightforward retail, to higher risk clients (including PEPs) and clients who use complex structures.

Who Should Attend

  1. Financial Institutions regulated by the FCA including those falling under EMI, PSD and MIFID.
  2. Anyone who onboards new clients for financial transactions as described under the MLR 2017.
  3. Anyone with an interest in the subject especially “Relevant persons” under the UK MLR 2017, i.e. Estate Agents etc, as below
  • Where previously only holders of a casino operating licence were covered by the regulations, they now pertain to all gambling providers
  • Trustees now have greater obligations in relation to revealing the beneficiaries of trusts
  • Those engaging in financial activity on ‘an occasional or very limited basis’ are not covered by the regulations. ‘Occasional or very limited’ is defined as:
    • annual turnover from financial activity of less than £100,000 (this figure was previously £64,000)
    • activity limited to transactions not exceeding EUR 1000 per customer
    • financial activity ancillary to a larger business
    • financial activity not more than 5% of the total turnover of the larger business
    • financial activity only offered to customers of the main business
Knowledge Pre-requisites
None required
from £250 pp – Minimum 5 persons

Format

  • Duration is as a full day classroom workshop – Your Venue or we can arrange local venue at additional cost.
  • Attendees can also purchase our AML & CTF Policy & Procedures Document at 50% discount

Call us on 0207 097 1434

Or complete the form below

[ninja_form id=7]

AML – New Entrant Programme – Suitable for all firms with AML responsibilities, i.e. Estate Agents etc

aml template policy procedures ctf money laundering

AML & CTF New Entrant Programme 

Suitable for any firm with AML responsibilities like Estate Agents etc

The UK is one of the world’s largest and most open economies, whose strength is built on extensive and productive relationships across the globe. Ministers have the responsibility for national security and financial services, so they want the UK to continue to be an attractive country for legitimate business and a leading global financial centre. But they also recognise that the UK’s openness and status as a global financial centre exposes it to the risk of illicit financial flows.

Money laundering and terrorist financing are significant threats. Recent terrorist attacks in London, Manchester and elsewhere highlight the importance of the fight to deprive terrorists of the resources they need. Serious and organised crime has been estimated to cost the UK tens of billions of pounds every year. That is why we must continue to crack down on dirty money, strengthening the UK’s security and prosperity as well as that of our partners overseas.

What Makes Compliance Consultants Courses Different?

  • for over 20 years and have a first class reputation for delivering excellent value-for–money training
  • Our consultants are practicing compliance specialists and have industry qualifications and many years experience
  • This is a core competence for us and we are certain nobody trains more effectively than we do when it comes to this topic
  • The course director is an acknowledged subject matter expert and is also a Master Trainer
  • The workshop involves real life case studies and discussion sessions, with delegate involvement encouraged at all times
  • We don’t use academics as trainers. All our trainers are experienced practitioners who achieved at least senior management status over long careers
  • Your course director has been in the industry for over 30 years and has owned and/or operated financial services consultancies
  • We are judged solely by our results and we are proud to say that delegate feedback over many years has always been excellent

Objectives

  • Appreciate why AML & CTF are important
  • Understand how to complete an initial risk assessment
  • Appreciate the importance of effective controls and oversight
  • Recognise what an effective process should look like
  • Understand what “good” client on-boarding looks like
  • Realise that CDD is a process not just a tick box exercise
  • Recognise the importance of embedding CDD into the business as a normal business procedure as swiftly as possible
  • Recognise that business should never be taken on at the expense of compliance
  • Conversely, that compliance should not become just a business blocker

Course Content

  • What is AML?
  • The £40Bn scale of the problem
  • Why does it matter?
  • The three stages of money laundering
  • The three lines of defence model
  • Customer due diligence
  • KYC, CDD, EDD & DDD
  • A,B, C & D obligations Customer due diligence measures
  • High risk customers
  • Sanctions

Who Regulates This?

aml policy template
AML Policy & Procedures – Buy Now!
  • What must institutions have in place?
  • Why is compliance important?
  • Who sets the rules?
  • Regulators
  • BIS
  • FATF
  • Wolfsberg
  • Transparency international
  • JMLSG
  • Who polices the rules?
  • The US dimension
  • Clear policies and procedures
  • Senior management setting the tone
  • The role of the Compliance Head and the MLRO

The UK’s Initial Risk Assessment and the Risk Based Approach

  • Risk assessment methodology
  • What services/products would be attractive to a criminal?
  • Risk categories – standard, medium, high
  • Key controls
  • Sign off
  • Intensity of CDD
  • Review frequency
  • Transaction monitoring
  • The review process
  • Trigger events
  • The 3 lines of defence working as a team
  • Case study/Example

CDD, KYC, IDV, EDD & DDD – What do These Mean?

  • The financial crime lifecycle
  • CDD – the process
  • KYC – getting to know the client
  • IDV – checking the facts independently
  • EDD – for higher risk relationships
  • DDD – For some categories of client/counterparties
  • Source of Wealth
  • Source of Funds
  • Anti Terrorist Funding
  • The review process
  • Trigger events
  • The 3 lines of defence working as a team
  • Case study/Example

Dealing with Non-Personal Entities or Challenging Relationships

  • PEPS& Associates
  • Public Officials
  • What is a non-personal entity
  • Corporates
  • Trusts
  • Charities
  • Not for Profit Organisations
  • Money services business
  • Offshore relationships
  • Transparency – ensuring you have an end to end view
  • Ultimate beneficial ownership – 25% or 10%
  • Non face to face clients
  • Overseas clients
  • Jurisdictional risk
  • Case study/Example
aml money laundering risk

Sanctions

  • What are they?
  • Who sets them?
  • Who can be sanctioned?
  • Zero tolerance
  • Sanction types
  • Comprehensive/country
  • List based
  • Activity based
  • Sanction screening
  • Onboarding
  • Review
  • Payments
  • Real time (in-flight) versus non real time
  • Commercial providers –Worldcheck, Oracle
  • Sanction alerts
  • Sanction breaches
  • Payment stripping
  • Re-submits
  • Case study/Example

AML Typologies

  • How is money laundering completed in practice
  • “Professional” criminals want to stay under your radar
  • Placement risk easier to manage
  • Layering is a bigger vulnerability
  • Smurfing
  • Co-mingling
  • Multi banked
  • Overpayments
  • Underpayments
  • Changing quality and quantity
  • Other common methods
  • Case study/Example

Transaction Monitoring  – The Safety Net

  • Swim- lines and alerts
  • Who generates alerts & why?
  • What should prompt an alert?
  • Doesn’t make sense
  • Doesn’t fit our knowledge of the client
  • Doesn’t fit in with normal business activity
  • You have a bad feeling/misgivings
  • First line alerts
  • Second line alerts
  • Sanction alerts
  • Alert options
  • Accept
  • Seek more information
  • Escalate immediately
  • The importance of getting more information where applicable
  • Balancing the risk of tipping off with information gathering
  • Case Study/Example

Escalation Process

  • SAR’s or an internal intermediate stage – the pros and cons
  • Methods of escalation
  • Direct to MLRO
  • Via line manager
  • Via a confidential email
  • Whistleblowing
  • Essential SAR information
  • What does the MLRO do with alerts?
  • When must we involve specialist sanctions colleagues?
  • Deciding to escalate to the NCA
  • Time limits for escalation
  • Personal and potentially criminal liability of all parties
  • What happens once an SAR has been raised?
  • What happens next?
  • The mitigation process
  • The exit process

Other Key issues

  • Staff training – must be risk based
  • Creating a holistic, not process-based regime
  • Embedding escalation into “business as usual” processes
  • False positives
  • Ensuring the level of escalations are appropriate to the profile of the business
  • The role of internal audit
  • The MLRO report
  • Checking it all works well
  • Senior and top management oversight
  • Case study/Example

Course Conclusion

Wrap up
Summary
Open Forum

Background of the Trainer

Course Director

Lee has worked with a range of organisations from smal start-ups through to FTSE100 companies, including foreign banks and institutions, many that have had difficulties identifying and managing compliance risk, and helped them develop effective, robust systems. He has adapted his experience to develop this course and supporting materials with the practical skills based focus. Lee’s skills, qualifications and experience make him ideal for supporting anyone wishing to develop top-class knowledge in the management of Anti-Money Laundering and Counter Terrorist Financing.

Course Summary

As a new entrant to either the financial services industry or other businesses required to have in place effective AML & FCC controls, the range of requirements and responsibilities can seem overwhelming. There is also a danger of thinking AML is the only, or at least the biggest risk facing a firm. This is not true but it is a very high profile risk and the consequences of poor management or failure are very severe in both reputational and financial penalty terms. The MLR2017 has widened the scope considerably for AML procedures so that virtually all cash or near cash handling institutions have a responsibility to prevent financial crime.
At the heart of a successful AML process is a risk assessment, leading to a risk-based approach and a clear system for on-boarding new clients as well as reviewing existing relationships.  This workshop style, highly interactive course describes what “good” looks like, how to achieve it and how to understand why it is such an important feature of corporate governance.

Who Should Attend

Anyone with an interest in the subject especially “Relevant persons” under the UK MLR 2017, i.e. Estate Agents etc;
  • Where previously only holders of a casino operating licence were covered by the regulations, they now pertain to all gambling providers
  • Trustees now have greater obligations in relation to revealing the beneficiaries of trusts
  • Those engaging in financial activity on ‘an occasional or very limited basis’ are not covered by the regulations. ‘Occasional or very limited’ is defined as:
    • annual turnover from financial activity of less than £100,000 (this figure was previously £64,000)
    • activity limited to transactions not exceeding EUR 1000 per customer
    • financial activity ancillary to a larger business
    • financial activity not more than 5% of the total turnover of the larger business
    • financial activity only offered to customers of the main business
Knowledge Pre-requisites
None required
from £250 pp – Minimum 5 persons

Format

  • Duration is as a full day classroom workshop – Your Venue or we can arrange local venue at additional cost.
  • Attendees can also purchase our AML & CTF Policy & Procedures Document at 50% discount

Call us on 0207 097 1434

Or complete the form below

[ninja_form id=7]

Significant Rise In RegTech Costing Forecast By 2023

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This is according to a new report from Juniper Research, which estimates that spending on RegTech solutions, specifically, will escalate from an estimated $18bn (₤ 14bn) this year to $115bn (₤ 100bn) by 2023.

Financial commitment is forecast to go up by an average of 45% per annum over the next five years, far more than the 17% invested in compliance as a whole, reflecting a rapid change far away from traditional compliance options.

The Regulatory Compliance Paradox
The aggregated expense of regulatory compliance around the financial business sector is approaching $80BN globally. Yet compliance specific risks continue being at all-time highs.
Why would this be? Solely due to new regulations recommended immediately after the 2008 financial crisis mandate firms to gather, aggregate and fca template compliance manual risk management fca handbookreport unprecedented amounts of data, and combine complicated principles into their business operations. And yes, these rules are open to diverging translations and not consistently harmonised globally. But at the source of the enigma is the industry’s severe state of technology fragmentation: often within a single organisation, the same data is presented in many different ways using many different systems.
This can commonly cause highly complex regulatory setups that have escalated in to uninhibited costs, even so without having certainty of compliance: exactly how do you prove obedience to a rule, when the reasoning is hidden deep into a maze of inconsonant systems? This opacity at the same time challenges regulators’ supervisory mandate and might potentially affect market transparency.
Having this rise in complication and antiquated systems showing the existentialist and antique beliefs, it is predicted that RegTech will represent 40% of businesses total compliance spending by the year 2023.
The conclusions arrive as businesses start adhering to General Data Protection Regulation (GDPR), which came into law earlier this year and could possibly hit companies with fines worth up to 4% of their global annual turnover.
“Any heavily regulated business sector not prioritising RegTech adoption would risk damaging fines from failing to keep pace with regulatory changes,” Juniper warned.
After checking multiple technologies for estimated timescale of consequences and costs barriers, Juniper concluded that cloud computing is currently one of the most disruptive force in the RegTech sector.
The most recent report argues that transitioning to cloud-based compliance is a “crucial precursor” to other regulatory modern technology approaches, for instance, artificial intelligence and big data.
“Unless businesses effectively plan the correct cloud deployments, they will struggle to utilise the advanced technologies required to meet future compliance challenges,” Juniper said.
This comes after Claranet UK found that over half of the UK’s financial sector is at this time struggling to understand and act upon the customer data they accumulate.
Legacy systems are considered to be one of the main reasons behind the findings, with cloud technologies indicated as a way of remedying the predicament. Traditional spreadsheet systems have lots of inherent risks and need to be migrated to a more powerful and scalable system, because as we all know, if we don’t grow; our businesses, continue to adapt to new ways of operating, our business will become hardly a footnote in history.
Lee Werrell
Compliance Doctor
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Infographic on 16 Blockchain Disruptions

Blockchain technology is probably one of the most impactful discoveries in the recent history.

After all, it has a massive potential to change how we handle online transactions. Despite some skeptics, the majority of experts agree that blockchain has the potential to disrupt the banking and financial industry, and many other ones!

But what is this technology exactly? We at BitFortune.net will try to explain that in Layman’s terms, as well as provide you with insights into how different industries can benefit from blockchain.

To put it simply, blockchain enables decentralized transactions across a P2P network. There is no need for a middleman, resulting in almost instantaneous operations and most importantly, low fees. Plus, transactions carried out through a blockchain are much more secure, transparent, and private.

As mentioned earlier, different industries will have different benefits from implementing blockchain technology, and that is what this infographic is all about. For example, the banking sector will get faster transactions, lower costs, improved security, and better record keeping. Also, the blockchain technology can improve electronic voting systems. With this technology integrated into a voting system, governments won’t be able to tamper with votes because blockchain creates publicly viewable and singed transaction that can’t be changed or rewritten.

This infographic will help you understand how the blockchain technology can and will improve 16 different industries, from music to government. So, read on and find out what their future will look like. Article by bitfortune.net.

You may also be interested in “How To Invest In Bitcoin”

How About Travelling With Bitcoin? 

58 INSANE FACTS ABOUT BITCOIN [INFOGRAPHIC – UPDATED JANUARY 2018]

58 INSANE FACTS ABOUT BITCOIN [INFOGRAPHIC – UPDATED JANUARY 2018]

Bitcoin’s Bumpy Ride
 
Bitcoin, one day it’s skyrocketing, then it loses half of it’s value within a few hours. Then it strengthens again, despite critics stating that the bubble had burst. Where will the currency head next?
Buckle up, Buttercup! As a Bitcoin investor, you are in for a bumpy ride. It gives the term Bitcoin gambling a whole new spin.
There are people who believe that the currency could end up rising to close to the $100,000 level, but it does not look like that will be anytime soon.
The focus of governments worldwide is to start clamping down on cryptocurrencies in general. This has been especially bad news for miners and cryptocurrency traders in China. Early in 2018, the Chinese government banned Initial Coin Offerings, a way for startups to raise funds.
This was to be expected – the ICO market has been too unregulated for too long – it’s like the Wild West of the investment world with people playing fast and loose with cryptocurrency.
The shock move was when the Chinese government banned all trading of cryptocurrencies as well. Also, they put forward a plan to start discouraging Bitcoin mining.
Now, considering that around about 81% of Bitcoin’s hash rate is controlled by Chinese miners, this is a very real concern.
Why all the animosity toward Bitcoin by the government? For starters, Bitcoin is largely unregulated. It is not one single organization that can be easily controlled, but a network of nodes spread worldwide. With peer-to-peer transactions, money can be moved globally without needing to notify the authorities.
China, though, has another big problem when it comes to Bitcoin mining. It was seen as the ideal location because power and labor are cheap, and you have easy access to the most advanced computer chips.
The downside is that this process draws a lot of power. This causes problems for a country already battling with carbon emissions. It’s in the government’s interest to shut the miners down for this reason alone.
Interested in learning more about Bitcoin? Read on.

Does the UK government’s new National Risk Assessment avert recognising important systemic weakness?

Are Their Important Changes That Weaken The UK NRA In Advance Of Brexit?

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The UK’s original 2015 National Risk Assessment on Money Laundering and Terrorist Financing (NRA) presented an honest, if quite broad and superficial, idea of the ML and TF risks in the UK, in an attempt to ‘inform the efficient allocation of resources and mitigate those risks’.

This showed intelligence disparities, a shaky reaction to money laundering by law enforcement ‘for an extended period of time’ and weaknesses in supervision. These discoveries have shaped a variety of responses, featuring an Action Plan for anti-money laundering and counter-terrorist finance (AML/CTF) and an AML supervisory review. Further efforts to reform the UK’s Suspicious Activity Reports regime have also been advancing.

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Behind much of this particular activity is the concealed hand of the Financial Action Task Force (FATF), the global standard-setter for AML/CTF, which will determine both the specialised compliance and effective application of the UK over the next six months before publishing its assessment in 2018.

By having this in mind, the British government published a modified NRA that lays out how the key ML and TF risks for the UK have modified since the previous edition, and the action taken since 2015 to address these risks.

While presenting some welcome learning (for example the sectoral adjustment of charities from ‘medium-high’ to ‘low’; the inclusion of capital markets ML risks; and the inclusion of the TF threat from Northern Ireland-related terrorism) and showcasing some notable legislative developments (in particular the Criminal Finances Act 2017 and the Money Laundering Regulations 2017), the NRA still overlooks some vital risks, particularly the ability of law enforcement to respond to the identified threats.

It is not clear, and indeed insufficiently delineated in the NRA itself, how this nuanced view of risks, that some services, in some circumstances, pose a high risk, can be exercised

The 2017 NRA has made a welcome attempt to focus more on activity that creates risks of money laundering, instead of taking a strict sectoral approach. In comparison to the 2015 NRA, the new document has chapters including accountancy, legal, and property/estate agency services, as opposed to the associated sectors (like accountancy services providers in 2015).

It also identifies that higher risks may emerge where these professional services correspond and that separate sectors can virtually offer the same services (such as company formation or use of client accounts).

fca operational risk management rules mapping handbookA distinction is drawn when comparing abuse of property itself and the provision of estate agency services. Nonetheless, the NRA stops short of analyzing these higher risk environments thoroughly. It thus seems inevitable that the risk ratings allocated to certain services, for example, accountancy services rated overall ‘high’ for money laundering, will be connected into customer risk models as a sectoral risk.

One remarkable element concerning this assessment is the downgrading of estate agents from medium to low risk given the sector has shown substandard awareness and compliance and is now tasked with due diligence on both sellers and buyers. The vulnerability posed by this sector is added to due to the difficulties HM Revenue and Customs (HMRC) face in supervising such a diverse sector. This regrading will seem obtuse to many and may reverse the efforts made to enforce greater compliance with ML regulations over recent years.

Money service businesses (MSBs) stand out from the NRA: in form, given that MSBs are not discussed with other financial services, but inserted between cash and non-profit organisations; and in substance, because the ML risks related to the MSB sector have been re-evaluated from medium to high.

The justifications for this adjustment include challenges for the sector’s effective supervision by HMRC; and several cases corroborating the view of law enforcement agencies that complicit MSBs are ‘a favoured and readily available money laundering vehicle for organised crime groups’.

The UK government will be evaluated mainly by FATF on whether or not it has the capacity to strengthen the MSB sector’s supervision in the UK in such a way in order to restore banks’ confidence in the sector.

Most importantly, the NRA recognises MSBs’ growing difficulties accessing banking services have even further reduced the transparency of the sector composition and operations.

The NRA refers to several of the government’s responses to these findings, including at the international level. However, as said above, the government will still be judged predominantly by FATF on whether it is able to strengthen the MSB sector’s supervision in the UK in such a way as to restore banks’ confidence in the sector. Ultimately, this will reduce the risk mitigation costs incurred by banks that provide services to MSBs.

A persistent theme through both NRAs is the importance and challenge of effective supervision. One innovation since the 2015 NRA, which identified several vulnerabilities in the UK’s supervisory regime, has been the formulation of the Office for Professional Body AML Supervision (OPBAS).

This takes into account the fact that 22 of the UK’s 27 watchdogs are professional body supervisors (rather than statutory bodies such as the Financial Conduct Agency and HMRC) that display an inconsistence, and sometimes ineffective, treatment.

Up and running at the end of 2017, OPBAS look after ‘the adequacy of the AML/CTF supervisory arrangements of professional body supervisors in the UK.’

Digital currencies remain a ‘low risk’ for both ML and TF, mirroring the continued lack of significant evidence of their greater use by organised criminals and terrorists

Greater supervisory rigour and coherence is clearly called for, yet as both the MSB and estate agency cases imply, it is not merely professional body supervisors that ought to display greater commitment to creating an effective deterrent to preserve the integrity of the system.

The NRA singles out e-money, digital currencies and crowdfunding as products that are most ‘relevant from the perspective of ML and TF’. TF risk for e-money increases from ‘low’ to ‘medium’ in response to emerging evidence of terrorists’ intent to exploit pre-paid cards to transfer funds across borders undetected.

A welcome addition is the recognition of the potential for FinTech to mitigate financial crime. This is positive, and mirrors the important work undertaken through the FCA’s regulatory ‘sandbox’ that has allowed enterprises to test products in an unencumbered environment. These opportunities, specifically in the regulatory technology (RegTech) space are likely to increase, thus an acknowledgement in the NRA is timely.

compliance consultant consultancy supportAlthough new laws and initiatives for example, the Joint Money Laundering Intelligence Taskforce feature prominently, there is a striking omission from the NRA. Risk assessments should not only identify the risks at hand, but also the extent to which they can be mitigated (the control measures). The 2017 NRA has, perhaps intentionally, side-stepped talking about the latter given it is here the UK is found wanting.

The NRA 2015 noted that ‘the law enforcement response to money laundering has been weak for an extended period of time’. The degree to which this weakness has been addressed is left open in the most recent Risk Assessment, with talk about ‘enhancing the law enforcement response’ limited primarily to updates on legislation.

With police budgets chopped by 20% since 2010 at the same time as law enforcement is being asked to answer a greater array of strategic threats, the levels of resource delegated to investigate complex (or perhaps simplistic) money laundering cases are decreasing.

Ultimately, a successful AML/CTF regime has to do with delivering results. The jury is out and will return with its verdict a year or so from now.

For all your UK regulatory compliance needs, including AML specialist services, go to Compliance Consultant (http://www.complianceconsultant.org), One of the UK’s Leading Consultancies. Buy their top-selling AML & CTF Policy & Manual at https://goo.gl/qLdQ39.

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MIFID II What Compliance Wealth Managers & Advisers Need To Get In Place

MiFID II finally comes into effect on 3 January 2018

Although there may still be some grey areas, it is time to make sure you have your compliance arrangements in place or being progressed so that there are no nasty surprises.

Get a PDF of this post from this link (right click and “download as…”)

Here are 11 things we suggest wealth managers, asset managers or independent financial advisers do to best prepare themselves ahead of the New Year deadline:

1. Not only make a register of all conflicts of interest, but also articulate how these are mitigated or managed and review them, at least annually.

2. Review whether your firm needs additional qualifications, training or Part IV permissions to maintain independent status.

3. Structured Deposits: * HOTSPOT* Apply for new permissions by 2 January 2018 if you wish to advise on these.

4. Carefully consider your recruitment procedures and ascertain if they need tightening (consider SM&CR impacts too).

5. Conduct Risk: Review your remuneration structure and ensure no incentives negatively impact clients.

6. Decide which staff the “Personal Account Dealing” rule should apply to, and create a register of direct equities they hold.

7. Create or amend your Personal Account Dealing policy to reflect the need to report staff holdings changes.

8. Legal Entity Identifier: * HOTSPOT* Decide if you need to apply for this through the London Stock Exchange.

9. Confirm if your discretionary fund manager (DFM) or platform will offer online reporting access and thereby avoid the need for time consuming paper reporting.

10. Ensure you are comfortable with and confirm whether your DFM or platform will issue the 10% loss notification and how. This an extension of the COBS 16.3 rules (https://www.handbook.fca.org.uk/handbook/COBS/16/)

11. Check your agency agreement with your DFM where model portfolios are being used: does the responsibility for regular and ongoing checking of suitability sit with you as the adviser?

Legal Entity Identifier (LEI)
A key impact of the new regulations is that from 3 January 2018, an investment management firm will only be able to continue trading in financial markets on behalf of certain clients if those clients have obtained a LEI. If you have clients that are required to have an LEI, have you informed them of this? These entities include; Trusts (but not bare trusts), Companies (public and private), Pension Funds (but not selfinvested, personal pensions), Charities, and Unincorporated Bodies.

Note that investment trusts and ETFs are not excluded from the requirement for a LEI. Advisers might need to consider whether the cost of an LEI has any impact on a decision to use other than collectives in portfolios. The other point to note is that an LEI is NOT required if investment is being made exclusively in collectives such as investment bonds, OEICs or unit trusts.

How do you obtain an LEI?
The LEI can be obtained directly from the London Stock Exchange (LSE) for an initial fee of £115+VAT and there is an annual renewal fee of £70+VAT.

 

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Money Laundering Regulations 2017 Changes

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As you know, the 26 June 2017 saw the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”) came into force, having been made, laid before Parliament and approved all on 22 June 2017.

Regulated businesses are now faced with the inestimable task of ensuring both their firm-wide and client-specific risk assessment processes and procedures are sufficiently robust to comply with MLR 2017 – after the commencement date.

If you use an external Compliance Service, they may well have provided you with an update on the legislation before it came into force, however, anyone who used the original draft in the belief that they would be the final rules will have failed to identify key points that are required by firms, that have been changed or were introduced in the final legislation.

Questions You Need To Ask

1. Have we reviewed the definitions and procedures in accordance with the MLD4?
2. Have we updated the CDD/EDD/SDD and Beneficial owner sections?
3. Have we trained our staff on the changes?
4. Is our policy up to date?
5. Is our policy approved by the board?
6. Would our AML/KYC/FC preparations or current arrangements stand up to independent external scrutiny?
7. Do you need to review the ‘state of play’ within your firm?

If the answer to ANY of these questions is “NO”You Need Our Help.

After a comparative analysis of the draft Regulations and the final MLR 2017 from the draft published by HM Treasury in April 2017 there are key differences which we have identified below.

Risk Assessment & Review
At your business level, two risk assessments are required. A business-wide risk assessment of money laundering and terrorist financing geographical features, transactions, products and delivery channels, as well as a specific risk inquiry prior to the commencement of each client relationship and, following a consideration of customer type, indeed, during the course of the relationship.

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Governance Requirement
Regulation 19 of the Act shows a positive duty on regulated businesses to “regularly review and update” such policies and controls has been inserted in Regulation 19( 1)(b). Businesses will also be required to maintain a written record of all changes to AML policies, controls and procedures made because of a review plus all “steps taken to communicate” the changes to staff. This means that your version control is now of paramount importance. A similar requirement applies in Regulation 20 to parent companies in the UK, falling within the scope of a “relevant” (regulated) person.

Internal Controls
Alongside the requirement to implement and regularly review AML policies and procedures, is a requirement in Regulation 21 that regulated persons implement internal controls applicable to employees engaging with compliance matters. Previously, the draft Regulations required a firm to “carry out screening of relevant employees and agents” at regular intervals. “Screening” relates to assessing the skills, knowledge and expertise of a particular individual. The final version of the Regulations, however, has slightly lessened the compliance burden in one respect by dropping the reference to “agents” in Regulation 21.

Training records
A duty to maintain written records of training provided to relevant employees, which practically would include all fee earners and those in the Compliance function, also appears in Regulation 24. No such duty featured in this April’s draft Regulations.

Special Offers For Limited Number And/Or Date
If you want to get an up-to-date AML & CTF Manual, please click on this link (http://aml-compliance-manual-ofac-sanctions-ctf.co.uk) and use the code “CCMLD4” in the payment box.

Hurry because this only valid for the first 25!

If you want to take advantage of our policy checking offer, go to our special offer HERE but hurry, this is only on sale until the 31st August!

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