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MANAGING RISK of MONEY LAUNDERING and TERRORIST FINANCING (FINANCIAL…
MANAGING RISK of
MONEY LAUNDERING and TERRORIST FINANCING
Placement
PoC Entering the Financial System
Layering
Process in Which PoC are given the Appearance of Being Legitimately Sourced
Intergration
PoC Emanate in to the Legitimate Economy
Proceeds of Crime "PoC"
Money Laudering
This Term Can be Misleading Not Just Cash but any form of Assets Derived from PoC
There are Other Means of Handling PoC
Laundering
is the Process of PoC being turned into Assets Appearing Legitimately Sourced
Tax Evasion
Un-Declared Income/Capital Gains or Fraudulent Tax Returns
Unit 4 - Page 102
FINANCIAL CRIME RISKS
Fraud
Intellectual Property Fraud
Insurance Fraud
Computer Fraud
Investment Scheme Fraud
False Accounting
Asset Misappropriation
Money Laudering
Corruption
Terrorist Financing
Misleading Statements and Market Manipulation
Insider Dealing
Market Abuse
Objectives of Money Laundering
Disguise Criminals Identity
Concealing Ownership
Concealing Management & Control
Placing Distance Between Them & Property (Physically & On Paper)
Changing Nature of Money/Assets
Benefit Securely from Proceed of Crime
FATF
40 Recommendations
9 Special Recommendations
Revised 2012
Money Laundering PEP Example Unit 4 - Page 78
Internal Reporting Systems
Internal Reporting Line (Identification of the MLRO) who SAR's are reported to
MLRO to Have Access to all Systems to enable Evaluation of SAR
Preferable that Initiating Staff Member to be Identified on SAR
MLRO to Acknowledge Receipt of SAR (Written)
Supervisors/Managers Routinely Updated
MLRO to Externally Report
Risk Based Approach to Money Laundering
Assess Risk of Products & Services
Customer Base
Geography
Policies & Procedures
CDD
PEP's
OFAC Sanctions
Unit 4 - Page 88
Effective Internal Reporting Sytem
Failure to Report
Tipping Off
Effective MLRO
Receive SAR's
Evaluate Internal SAR's
Investigate (WWW/Internal)
Assess SAR and Decide if it should be Externalised
Liaise with Law Enforcement on Disclosure
Unit 4
Page 86
ML Example Unit 4 - Page 74