AntiMoney

Anti MoneyLaundering/Counter
Laundering/Counter Terrorist
Terrorist Financing
Financing Training
Training
AGENDA
What is Money Laundering? SERVING THE
INTERNATIONAL
What is Terrorism? TRAVELLER
WORLDWIDE
Company & individual responsibilities

CATCH

Disclosure requirements and LT forms

ID requirements

Authorization limits, transaction review &

record keeping

Suspicious transactions and SARS forms

OBJECTIVES
By the end of the workshop, you will be able to:-
SERVING THE
Understand what Money Laundering/Terrorist INTERNATIONAL
Financing is TRAVELLER
WORLDWIDE
Understand and explain the 3 stages of Money AML POLICIES
Laundering & PROCEDURES

Describe the responsibilities of The Change

Group as a company and as individuals to comply C.A.T.C.H
with AML law

Explain each section of the acronym CATCH MLRO

Understand the reporting requirements and
who is the MLRO/Nominated Officer
OBJECTIVES
Explain which identification is acceptable for
all transactions ID ACCEPTED
SERVING THE
INTERNATIONAL
Fully understand the Large Trade form and TRAVELLER
when it is necessary to complete WORLDWIDE
LARGE
TRADE
Know when to gain authorization for Large
FORMS
Trades and from who

Explain what could be a Suspicious Transaction

SUSPICIOUS
and how to complete the form TRANSACTIONS

What to do once a LT or a SARS form has been

completed SARS

Pass the AML assessment with pass mark of

80%
 What is Money Laundering ?
Money Laundering is the process by
which criminals attempt to conceal the SERVING THE
true origin and ownership of the INTERNATIONAL
TRAVELLER
proceeds of illegal activities WORLDWIDE

To disguise the (illegal) source of funds.

To (attempt to) erase the link between the

money and the illegal activity.

SIMPLY PUT: PROCESS OF

MAKING DIRTY MONEY LOOK
CLEAN
 What is Terrorist Financing ?
Terrorist activity financing may involve funds raised
from legitimate sources, such as personal donations SERVING THE
and profits from businesses and charitable INTERNATIONAL
organizations, as well as from criminal sources, such as TRAVELLER
Terrorism
the drug trade, the smuggling of weapons and other WORLDWIDE
Is the use of threat or
goods, fraud, kidnapping and extortion. action to influence the
Government, or to
intimidate any section of
the public, or to advance
Terrorists use techniques like those of money a political, religious or
launderers to evade authorities' attention and to ideological cause where
protect the identity of their sponsors and of the this would involve
violence, threats to
ultimate beneficiaries of the funds. However, financial health & safety, damage
transactions associated with terrorist financing tend to to property or
be in smaller amounts than is the case with money disruption of electronic
laundering, and when terrorists raise funds from systems.
legitimate sources, the detection and tracking of these
funds becomes more difficult.
What is Money Laundering?
SERVING THE
If erasing this link is successful: INTERNATIONAL
TRAVELLER
WORLDWIDE

Can not see the true source of the funds and

may not perceive that person as someone
who benefits from illegal activity

Consequently, the illegal funds appear

legitimate
Money Laundering – Source:
(illegal) activities
SERVING THE
Robbery Kidnapping
INTERNATIONAL
and Fraud TRAVELLER
WORLDWIDE

Counterfeiting and Drug Trafficking

Forgery

Tax Evasion Bribery /

Corruption

White Collar Organised

Crimes (including Prostitution
Crime
Insider Trading and
Securities offences)
Extortion Smuggling
(arms, people, goods)
 STAGES OF MONEY
LAUNDERING SERVING THE
REMEMBER
INTERNATIONAL
1. PLACEMENT: The physical disposal of cash proceeds
TRAVELLER
derived from illegal activity. Staff should
WORLDWIDE
always be alert
to the possibility
2. LAYERING: Separating criminal proceeds from their of illegal
illegal source by creating many layers of financial transactions
transactions. This disguises the audit trail and provides resulting in
anonymity. Money Laundering
and/or
3. INTEGRATION: The provision of apparent legitimacy criminal activity
to criminally derived wealth. If the layering process has
succeeded, integration places the laundered money back
into the economy in such a way that the money reenters
the financial system as normal business funds.
 STRUCTURING
or Smurfing as it is also known is an ML technique
which involves the distribution of a large amount of cash SERVING THE
into a number of smaller deposits to evade threshold
INTERNATIONAL
reporting requirements.
TRAVELLER
Structuring is also used to layer funds into amounts in an
WORLDWIDE
attempt to avoid scrutiny through international wire
transfers reporting.

Common methods of structuring include:

• regularly depositing similar amounts of cash, which are

below a country’s reporting threshold disclosure limit

• the use of multiple financial institutions or branches of a

financial institution often within short timeframes

• the use of third parties to deposit funds into single or

multiple accounts.
Money Laundering – Three stages

SERVING THE
INTERNATIONAL
TRAVELLER
WORLDWIDE
Obligations & Responsibilities
It is a legal responsibility and therefore The Change Group
policy to prevent money laundering and terrorism SERVING THE
INTERNATIONAL
financing by: TRAVELLER
WORLDWIDE
MAIN PIECES OF
Adhering to the money laundering and terrorism LEGISLATION
financing laws
Anti-Money Laundering
Being fully compliant with rules & regulations and Counter Terrorism
Financing Act 2006
Adherence to TCG AML/CTF policy documents (AML/CTF Act)

Remaining vigilant to all customer and transaction

activity
Obligations & Responsibilities
TCG will only conduct business with reputable
customers involved in legitimate activities SERVING THE
INTERNATIONAL
Every staff member is responsible for following and TRAVELLER
complying with procedures required by law and WORLDWIDE
implemented by TCG. MAIN PIECES OF
LEGISLATION
 The MLRO is responsible for monitoring the record
keeping of transactions conducted. Anti-Money Laundering
and Counter Terrorism
Operations, Deputy Managers and Team Leaders are Financing Act 2006
required to assist in the monitoring of transactions. (AML/CTF Act)

The MLRO ensures that Operations Managers take

responsibility for the day-to-day compliance of the
AML/CTF program.
What are the risks?
Failure to understand and deal with
Money Laundering can lead to: SERVING THE
INTERNATIONAL
TRAVELLER
Personal liability in law which can result in personal
WORLDWIDE
conviction of an offence and punished by a fine or prison
sentence or both

 Financial loss (fines, litigation)

 Loss and damage to reputation

What do we have to do?

C – Control your business by
having AML systems in place
SERVING THE
Transaction limits INTERNATIONAL
TRAVELLER
WORLDWIDE
Verification

Authorisation limits

Internal reviews
Transaction Limits
TRANSACTIONS MIN CUSTOMER ADDITIONAL
REQUIREMENT DUE DILIGENCE VERIFICATION IF
REQUIRED

> $1,000 - 1 Form of SERVING THE

photo ID
INTERNATIONAL
- Verification of
address
TRAVELLER
WORLDWIDE
- Verification of
DOB
> $10,000 - 1 Form of - Occupation - Secondary ID
photo ID
- Reason for - Proof of address
- Verification of transaction
address - Source of funds - Proof of funds

- Verification of
DOB
P.E.P (any amount) - 2 forms of -Occupation
photo ID
- Reason for
- Proof of transaction
address
- Source of funds
- Proof of funds

- Authorised by
Compliance
Officer
Acceptable ID & verification
Primary Photo Proof of address Proof of DOB
ID
SERVING THE
 Passport  Drivers licence  Passport INTERNATIONAL
TRAVELLER
 Drivers licence  Drivers licence
WORLDWIDE
 Proof of Age Card
Authorization Limits

 > $2,500 < $20,000 Team Leader or above to

authorize SERVING THE
INTERNATIONAL
TRAVELLER
 > $20,000 < $250,000 General Manager &
WORLDWIDE
Compliance Officer to authorize

 > $250,000 + Board Director & Compliance

Officer to authorize
A – Appoint a Nominated
Officer/MLRO
Who is the MLRO for Austria? SERVING THE
Awais Anwar INTERNATIONAL
TRAVELLER
Who holds local responsibility? WORLDWIDE
Operations Managers

What is AUSTRAC?
The Australian Transaction Reports and Analysis Centre

What do they require?

TCG to verify the identity of customers
conducting transactions that exceed certain limits and also
report all transactions of $10,000 or any suspicious
transactions.
T – Train your staff

Training every 6 months SERVING THE

INTERNATIONAL
TRAVELLER
Pass AML assessment every 6 WORLDWIDE

months (pass mark 80%)

C – Confirm the identity
of your customers
SERVING THE
KNOW YOUR CUSTOMER (KYC) INTERNATIONAL
& TRAVELLER
CUSTOMER DUE DILIGENCE (CDD) WORLDWIDE

 Obtaining information about a customer over and above

the required ID information in order to effectively identify,
verify and monitor customers and transactions.

The purpose of this is to reduce the risk of you business

being used for money laundering.

 By asking questions such as reason for the transaction,

source of funds & nature of the activity can increase the
likelihood that you will detect suspicious activity.
Know your customer - KYC
Politically Exposed Persons (PEP)
Are individuals who are or have been entrusted with
prominent public functions in a foreign country, for
example Heads of State or of government, senior
politicians, senior government, judicial or military
officials, senior executives of state owned corporations,
important political party officials. Or persons who are
immediate family members or known to close associates
of such a person.
Consolidated Sanctions List

The EU operates a domestic counter-terrorism regime and

imposes financial restrictions on persons and entities; as a
result we must not accept these persons or entities as
customers.
The purpose of this legislation imposing financial restrictions is
primarily to prevent the diversion of funds to terrorism and
terrorist purposes.

All customer transactions of

$10,000 & above
must be checked
against the
sanctions list
H – Hold all records for at
least 7 years
SERVING THE
INTERNATIONAL
Large trade & SARS forms TRAVELLER
Match & check against IMX report WORLDWIDE

Match & check ID copies taken

Monitored & review weekly
Report any suspicious transactions.
 MUST

SERVING THE
THEY HAVE PERSONAL LIABILITY IN BREAKING
INTERNATIONAL
THE
TRAVELLER
LAW
WORLDWIDE
IN
AND TO CAN RELATION
TO
AML
RESULT IN CTF
BEING OF AN OFFENCE &
PERSONALLY PUNISHED BY A LEGISLATION

OR BOTH
ASSISTANCE
SERVING THE
Failing on AML
INTERNATIONAL
When an employee provides TRAVELLER
assistance to a person engaged in WORLDWIDE

money laundering to obtain, conceal,

Staff must follow
retain or invest funds and that
all AML
employee knows or suspects that the procedures laid
funds are proceeds of serious down In
criminal activities. Section 13 of
the Operations
Manual
TIPPING OFF
It is an offence for anyone to SERVING THE
prejudice an investigation by INTERNATIONAL
Failing on AML
TRAVELLER
informing the person under suspicion WORLDWIDE
that a disclosure has been made, or
Staff must
that authorities are acting or always be
proposing to act in connection with aware they
an investigation into money have a
laundering. The punishment on personal
conviction for this “tipping off” is liability in
law
imprisonment, a fine or both.
FAILURE TO DISCLOSE
SERVING THE
Failing on AML
INTERNATIONAL
In the case of drug trafficking and TRAVELLER
terrorist activity, it is an offence for any WORLDWIDE
person who acquires knowledge or suspicion Can result in
of money laundering in the course of their personal
trade, profession, business or employment conviction of
not to report the knowledge or suspicion as an offence
soon as is reasonably practical after the & punished
information came to their attention. by a fine, a
prison sentence
or both
WILLFUL BLINDNESS

DO NOT
SERVING THE
INTERNATIONAL
Is when a member of staff TURN A
TRAVELLER
WORLDWIDE
understands the AML regulations,
recording and requirements and
BLIND
then knowingly conducts a EYE!!
transaction without collecting the
appropriate information needed to
meet these requirements.
 WILLFUL BLINDNESS
Aiding or participating in money laundering

Fraudulent reporting of cash transactions The following

SERVING THE
INTERNATIONAL
constitutes
TRAVELLER
Deliberate non-reporting of cash transactions WILLFUL
WORLDWIDE
BLINDNESS
Deliberately not completing or submitting
required information

Not reporting suspicious transactions

Deliberate failure to complete a LT or SARS form

Deliberate failure to maintain adequate records

Deliberate failure to forward the LT forms and

documents to the Nominated Officer/MLRO
Suspicious Transactions REMEMBER

If youTHE
SERVING are
The following guidelines can be used as suspicious of
INTERNATIONAL
Suspicion indicators:- a transaction or
TRAVELLER
WORLDWIDE
a customer then
The customer is reluctant to provide details do not proceed
of their identity with the
transaction
The customer information provided is
inconsistent with what is already known about As soon as
possible fill in
the customer
all details on a
SARS Form and
The customer is unusually nervous and alert the
possibly hurrying the transaction. MLRO/Nominated
Officer
Suspicious Transactions
REMEMBER
SERVING THE
The ID given appears to have been altered in If you become
INTERNATIONAL
some way suspicious during
TRAVELLER
a transaction &
WORLDWIDE
are afraid of
The customer requests currency in large “Tipping Off”
denomination notes the customer
then you must
complete the
The customer will not disclose the transaction.
origin/source of cash
Once completed
The customer attempts to conduct more than you must fill
in a SARS Form
one transaction to keep individual amounts & send to the
just under the reporting limits MLRO/Nominated
Officer.
Suspicious Transactions
IF YOU HAVE A SUSPICION REMEMBER
SERVING THE
INTERNATIONAL
You must report it In both
TRAVELLER
circumstances
WORLDWIDE
You must complete a SARS form you must alert a
Team Leader
Regardless of the amount & other branches
or whether the transaction took place of the suspicion

Alert Team Leaders & other branches

Fax the SARS form
Inform MLRO/Nominated Officer to local branches
If possible
 LARGE TRADE PROCESS
Customer Ask the Take the money
wants to customer Check the ID &
& ID provided
buy for the count the money
by the
$10,000 relevant ID thoroughly
customer SERVING THE
INTERNATIONAL
TRAVELLER
WORLDWIDE
REMEMBER
Get LT Form REMEMBER Once you have
The LT form
and ask the To do KYC all the info
must be
customer for where is the required call TL
completed by
all details money from or above for
you & signed
required & what is it for? authorisation
by the customer

Do a final check
Go through Take a copy of
on cash in/out,
double check the ID to be Pay out to the
ID taken &
& authorisation attached to customer
LT form
process the LT form
completed
 SERVING THE
INTERNATIONAL
TRAVELLER
WORLDWIDE

AML TRAINING
EXERCISE

COMPLETE THE
SCENARIOS......
ANY QUESTIONS? SERVING THE
INTERNATIONAL
TRAVELLER
WORLDWIDE

ARE YOU READY

FOR THE TEST?!?
Thank You
Disclaimer
• The contents of this document together with all information concerning the property or
business affairs of the Employer or its clients and customers are confidential and the property
of The Change Group International plc.

• This document and all other company documentation should only be used by the person to
whom it has been supplied, and must never by copied, or passed on to any third party without
the prior written authorisation of The Change Group International plc.

• While the information, advice or comment is believed to be correct at the time of going to
print, its accuracy and/or completeness cannot be guaranteed.

• The Change Group cannot accept responsibility for any claims, subsequent or otherwise
arising from the use of this document. Always refer to current memos and correspondence for
up to date policies and information.

• For further details please contact your Operations Manager.

• © 2013 The Change Group International Plc. All Rights Reserved