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Feature: 1. It can increased car storage space, cell phone, credit cards, money, keys, coins etc., can be placed inside,prevent items dropping from seat gap . 2. Car Seat Gap Filler installs in 30 seconds. 3. Designed to fill the gap between car seat and console. 4. Pack with two seat leather storage box (one for the driver and another for the passenger).
Attention Please: Be cautious to order it before meaure your car seat gap .
Packing Include: 2x KYC car gap organizer* This Car Seat Gap organizer is great to keep your pocket necessaries organized for an enjoyable drive. This will save your countless time from digging between the seat and center console to find your dropped cell phone, credit cards, money, keys, coins, etc. the organizer is also easy to install convenient to use. * KYC car seat gap cather is measuring 13.78″ x 4.33″ x 2.17″ , This will fit most 75-80% vehicles, please check your car gap dimension to make sure there is still space for things to fit in. It’s made to be high standard which gives this Car Organizer a wonderful outlook and a super long life. * KYC Car seat side filler is made up with PU leather, gives the cather longer life, we have four colors optional. * The car caddy console is washable,when it is getting dirty after using for a long time, you can just put the filler into water to wash ,after wash please expose it under sunshine to dry it out. * Packing include 2pack KYC car gap organizer with bubble protection.when get the parcel please check the organizer and do a wash.
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Feature: 1.Special design for these people: * Children for fun in the evening Glow Party * Runners or Joggers * People walking their pets * Cyclists that can wear or slap wrap to any part of the bike * Outdoor activity that can slap wrap the band to the backpack * Campers * Slap to your wrist, ankle, arm.
Specifications: Product dimensions:13.58×1.50 inch Color: blue red orange Weight: 72g Material: nylon Color: red, yellow, blue, green, white,pink
Packing Included: 2 X KYC slap light【Light Weight Comfortable】designed with comfort in mind. The armBand is lightweight, keep people from some potential dangers when do morning walking, night time run, or dog walking. 【5 Using Mode】： This slap light have five mode to choose just according the sourounding: ON/ OFF/ FAST FLASHING/ LOW FLASHING/ STEADY 【Attention Please】:Attention Please: Before the first time use, please pull the plastic tab from the battery compartment(see picture) or the light will not turn on! The glow armband has bright light which keep people safe at night when do outdoor sports, like running, jogging, cycling, hiking,etc. 【Portable User-friendly】： Super Easy to use it by simply slapping against the wrist, arm or ankle, it will curl wrap automatically. The Slap Band is only 1.3 OZ. by weight. Fits for all ages. Comfortable on both children and adults and pets. 【Easy to Replace the Batteries】: This glow armband is reusable add a pull-tag to pull the PCB easily to replace the battery after used up, package with 2pcs the same color armband in a box.
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Advanced Medical Life Support (AMLS) is the leading course for prehospital practitioners in advanced medical assessment and treatment of commonly encountered medical conditions. Endorsed by the National Association of EMS Physicians, the course emphasizes the use of the AMLS Assessment Pathway, a systematic assessment tool that enables EMS practitioners to diagnose medical patients with urgent accuracy.
In the Second Edition of AMLS, students learn to recognize, assess, and manage common medical crises in patients. Topics covered include: respiratory disorders, cardiovascular disorders, shock, neurologic disorders, abdominal disorders, endocrine and metabolic disorders, infectious diseases, environmental-related disorders, and toxicologic emergencies.
Critical thinking scenarios encourage interaction and challenge students to apply their knowledge to realistic situations. During the scenarios, students: • Are at the patient’s side from arrival on scene to delivery to the hospital. • Assess, review, and discern the possible diagnosis of the patient. • Choose the next step to take on the AMLS Assessment Pathway. • Con¬firm the final diagnosis and provide ongoing prehospital management of the patient.
New to the Second Edition:
• Refined AMLS Assessment Pathway. • Clear emphasis on the BLS provider and integration with ALS throughout the assessment process. • Expanded content on highly critical patients. • Expanded content on environmental-related disorders. • Expanded content on infectious diseases.AMLS Advanced Medical Life Support
Are Their Important Changes That Weaken The UK NRA In Advance Of Brexit?
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.
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).
A 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.
Although 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.
Lee Werrell, Chartered FCSI, CEO of Compliance Consultant, explores the changes to risk assessment and the basic principles of the independent compliance assessment benefits effected by the new Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Money laundering Reporting Officers operating within the regulated sector will want to be aware of and appropriately integrate these two essential elements into their broader anti-money laundering and counter terrorist financing policies and procedures.
As regulators reinforce their focus on the ideal discharge of money laundering obligations involving customer due diligence (CDD) by the regulated sector, the changes introduced by the new Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, known as the Money Laundering Regulations 2017 or “MLR 2017” are of great seriousness. This is particularly true for money laundering reporting officers within the definition of Part 7 of the Proceeds of Crime Act 2002.
Risk assessment by the firm or business
Some of the key changes achieved by regulation 18 of the MLR 2017 relates to the obligation on firms and businesses working within the regulated sector to identify and assess the risks of money laundering and terrorist financing to which its organisation is vulnerable. This is easier said than done, since as being able to undertake this task, the risk assessor ought to have a sound grasp of the methods which criminals can use the firm’s services when handling the proceeds of their crimes. Criminals may range from organised criminals who are laundering the proceeds of drug trafficking and the like to white collar criminals who have paid or received bribes, committed fraud, breached economic sanctions, or trifled a spot of insider trading. It follows that a firm or business operating in the regulated sector may be vulnerable to money laundering or terrorist financing in a myriad of different ways. Regulation 18( 4) of the MLR 2017 requires a written record to be made from all steps carried out by a firm in the identification and assessment of its money laundering and terrorist financing risk.
Pursuant to regulation 19( 1 )(a) of the MLR 2017, the firm’s risk assessment of its susceptability must dictate the development of its policies, controls and procedures which have been designed to mitigate and manage effectively the risks of money laundering and terrorist financing. What’s more, under the regulation 21(c) of the MLR 2017, having regard to the size and nature of the firm’s business, a firm is now required to establish an independent audit function with responsibility to analyze and evaluate the effectiveness of the firm’s policies, controls, and procedures, to generate suggestions about them, and to check compliance with them.
The high quality of the firm’s risk assessment is therefore critical, because when it pertains to an individual who is obligated to apply CDD measures, regulation 28(12) of the MLR 2017 requires the analysis of the money laundering or terrorist financing risk posed by the clients or customer or the transaction in question to show, amongst other things, the level of risk which their firm has identified in the firm’s risk assessment. In short, the generality of the risk assessment completed by the firm in respect of its susceptability to money laundering or terrorist financing serves to inform the particularity of risk assessment undertaken by the individual in relation to the customer or client concerned. The improvement of a risk profile for a customer or client is typically put together by dedicated professionals in the risk/ compliance function. The risk profile helps the individual on-boarding the customer in their assessment of whether any grounds for suspecting money laundering or terrorist financing has emerged during the Know Your Customer (KYC) process. Medium sized and small sized firms may not be able to afford this luxury and in this instance, it is vital that the firm’s risk assessment is adequately comprehensive to provide a sound framework for the staff’s risk assessment of a customer or client to be informed and effective.
How is the firm’s risk assessment to be made?
In executing the risk assessment a firm must take into account risk factors relating to its clients, the countries, or geographic areas through which it functions, its products or services, its transactions, and its delivery channels. But how is the firm to know the nature and intensity of the risk posed by these risk factors? The MLR 2017 consider that the firm may be helped by taking into consideration information provided by the supervisory authorities. Regulation 17( 9) of the MLR 2017 offers that if information from a risk assessment completed by a supervisory authority would support a firm operating in the sector to accomplish its own money laundering or terrorist financing risk assessment, the supervisory authority has to, where suitable, make that information easily available unless to do so would be irreconcilable with restrictions on giving out relevant information under the data protection legislation.
Information from Government authorities is likely to be limited
Among the key troubles for government agencies is the significant deficiency in their levels of knowledge about how highly developed money laundering is committed when the financial markets are involved. In one of the main findings in the UK’s National Risk Assessment (“NRA”) of Money Laundering and Terrorist Financing published in October 2015, HM Treasury and the Home Office conceded that there were significant intelligence gaps relative to “high-end” money laundering. This type of laundering is specifically relevant to major frauds and serious corruption, where the profits are often kept in bank accounts, residential or commercial property, or other financial investments, in lieu of in cash. The NRA judges the danger in the banking sector to be significant, since around 60% of ongoing money laundering cases being investigated by HMRC have funds initially shifted through banks. The intelligence picture in other areas, such as high value dealers, gambling, and new payment methods, was judged as being mixed.
What information is available to a MLRO?
Most likely, if a firm’s policies, controls, and procedures are to come through with flying colours, the firm’s money laundering reporting officer will have to supplement the guidance as to risk factors contained in the MLR 2017 and provided by the supervisory authorities with some comprehensive investigation of their own. The typology and sector-specific reports released by the Financial Action Task Force (FATF) are a good starting place. In addition, a money laundering reporting officer can consult the evaluations of money laundering and terrorist financing regimes run by its member countries which the FATF publishes regularly. Having said that, to meet the regulatory requirement a lot more will should be done. Money laundering reporting officers will have to digest reports prepared by, amongst other organisations, FATF-Style Regional Bodies (” FSRB’s”) and annual reports prepared by the Council of Europe’s Moneyval, mining them for information about how particular types of business might be used for money laundering and terrorist financing purposes, and which jurisdictions are considered more prone than others, concerning the integrity of the client and the nature of the business in question. The United States Central Intelligence Agency publishes a Global Factbook, and some beneficial information is available on the Anti-Money Laundering Forum operated by the International Bar Association. Furthermore, there is a significant amount of information readily obtainable on the web which money laundering reporting officers can access. For example, there are publicly available indices from HM Treasury’s Office of Financial Sanctions Implementation, Transparency International’s Corruption Perception Index, the Foreign and Commonwealth Office’s Human Rights Reports, and UK Trade and Investment’s pages on overseas country risk and quality of regulation. The MLRO or appropriate compliance team member, can review this information, digging for it for relevant material which will advise the firm’s things to consider as to whether the risk of money laundering and terrorist financing inherent in the form of work undertaken and the country with which it is associated, is low, medium, or high.
One apparent resource for a MLRO sits within the firm itself. As firms progressively more focus the delivery of their services in specialist areas, the first line of defence should be well placed to support the firm’s risk assessment.
Just as a solicitor specialising in the financing of energy transactions will understand the extent of corruption and bribery within this sector, an estate agent with a practice based in Kensington will be strongly cognisant of the risks of money laundering which purchases by Eastern European oligarchs and politically exposed persons pose. As a starting point for assessing the risks of money laundering and terrorist financing in an enterprise operating in the regulated sector, the MLRO could begin the method of risk assessment by commencing the process of self-assessment. As a practical suggestion, you could always purchase an Anti-Money Laundering & Counter Terrorist Financing Manual as provided by Compliance Consultant at http://bit.ly/IYCAML.
Assessing risk on rationally defensible criteria
Where a firm grows its risk assessment in this manner, and includes in its policies, controls and procedures provisions which detail how the risk is to become managed, the requirement in regulation 19(3)(a) of the MLR 2017 to include risk management practices will be satisfied. Interestingly, this requirement falls short of the requirement laid out in Article 8(4) of the EC Fourth Directive on Money Laundering which specifically pertains to “the development of internal policies, controls, and procedures, including model risk management practices …” Although the reference to “model” risk management practices is not something which appears in the Financial Action Task Force Revised Recommendations, larger companies operating in the regulated sector will ignore this requirement at their peril.
Reliance on qualitative proficient judgment when creating risk assessments continues to hold, but there is an inherent subjectivity within this approach and there is a danger that perhaps its thought to be self-serving if challenged by a regulator in a case where a less obvious risk of money laundering or terrorist financing was not identified. The EC Fourth Directive on Money Laundering is seeking to support firms and businesses operating in the regulated sector to apply a more sophisticated course of action, by leveraging quantitively derived models which allocate risk scores calculated by algorithms which have been developed from analysis of AML scenarios and typologies.
Management consultancies have developed a variety of model risk management practices for application in anti-money laundering and counter-terrorist financing incidents. The application of model risk management in the assessment of money laundering and terrorist financing vulnerability will also aid a firm or business in the regulated sector when seeking to display that its risk assessment policies are effective pursuant to the independent audit requirement introduced in regulation 21(c) of the MLR 2017. There is, however, an important caveat which must be borne in mind. As the Joint Money Laundering Steering Group (“JMLSG”) has cautioned, “where a firm uses automated systems purchased from an external provider to allocate overall risk scores to categories business relationships or occasional transactions, it should understand how such systems work and how it combines risk factors to achieve an overall risk score.” The JMLSG adds that “a firm must always be able to satisfy itself that the scores allocated reflect the firm’s understanding of the [money laundering and terrorist financing] risk, and it should be able to demonstrate this to the [regulator] if necessary.”
As a cheaper solution to acquiring a scoring system from an external provider, it is open to MLROs to develop their own scoring system. This would involve allocating scores to a wide range of risk factors based upon information available internally and externally such as the nature of the client, the type of transaction involved, and the geographical location in which it is taking place. As an example of the flexibility inherent in the allocation of scores, the JMLSG notes that “firms may decide that a customer’s personal links to a jurisdiction associated with higher [money laundering and terrorist financing risk] is less relevant in the light of the features of the product they seek.” 
Independent Compliance Assessment
It is uncertain exactly what is required of a firm or enterprise operating in the regulated sector to establish an Independent Compliance Assessment. By introducing a requirement for the Compliance Assessment to be independent, the person performing this responsibility should be unconnected with the implementation or operation of the firm’s anti-money laundering and counter-terrorist financing compliance programme. The JMLSG suggests that the task can be undertaken “by, as an example, an internal audit function (where one is established), external auditors, specialist consultants or other qualified parties”.
From the 26th of June 2017, the new UK Money Laundering Regulations 2017 (“MLR17”) came into force placing new legal and regulatory requirements on Estate Agency Businesses (EABs).
It is my pleasure to announce that Compliance Consultant has created a solution to help EABs get up to speed and fully comply with the new rules.
The MLR17s are an amendment to the current legislation which has been enforced since 2007. ALL EABs must comply with these requirements which also bring into force a new statutory regulator which will regulate all EABs from both a financial crime and conduct perspective. Any EAB which fails to comply with the complex regulations will face financial and legal penalties from both a company and individual level.
Who Are We?
Compliance Consultant is a specialist Governance, Risk and Compliance firm, providing advice, support and guidance to regulated and non-regulated firms since 2000. We have a range of services tailored to support firms as they operate in regulated spaces. We work with Estate Agents, Payment Service Providers, Independent Financial Advisers, Consumer Credit Act companies, Banks and Stockbrokers. We have a range of solutions, designed for both large and small firms. Compliance Consultant embeds a risk-based strategic approach into its projects and operational decision-making, enabling our clients to be assured of sustainable success.
To sum up, there are new legal and regulatory requirements on Estate Agency Businesses (EABs). Any EAB which fails to comply with the complex regulations will face financial and legal penalties from both a company and individual level.
Find out if you are affected by clicking on this link and SIGN UP to our 5-day series of pdfs covering how, what, when, where and why.