2012 Effective Risk Based Anti-Money Laundering Controls - Programme

Programme

09.30 Registration and coffee


09:45 Regulating Anti-Money Laundering and why is Anti-Money Laundering (AML) important

  • Basic illustrations
  • How much money is being laundered?
  • Innovative fraud
  • Money Laundering, an international problem
  • UK response
  • Countering the Finance of Terrorism (CFT)
  • How is the FLA involved?

10:15 The AML UK Legal & Regulatory requirements

  • Who do the regulations apply to?
  • Financial Services Authority (FSA)
  • The FSA perimeter
  • POCA 2002: Primary & Secondary Offences
  • The Objective Test
  • Tipping Off
  • Serious Organised Crime Police Act 2005
  • Principles based regime (including disciplinary cases)
  • Recent FSA Fines
  • Her Majesty’s Revenue & Customs (HMRC), as a regulator

11:00 Case study

11:30 Tea break

11:45 The Risk Based JMLSG Guidance Notes

  • A risk based approach- overview of the sector
  • Core Obligations
  • Identifying and assessing the risks faced by the firm/Group
  • Implementing controls to identify, manage and/ or mitigate the risks
  • Monitoring, reporting and improving the effective operation of the firm’s controls
  • Impact on the Money Laundering Reporting Officer (MLRO)
  • Dynamic risk management
  • Elements of a basic risk management system

12:15 The Suspicious Activity Reporting regime (SAR)

  • The SAR Consent system, objectives and expectations
  • Defining “Knowledge” and “suspicion”
  • Effective AML reporting: internal and external
  • The Consent issue
  • Keeping Records
  • Non-UK Offences
  • Data Protection Issues
  • Common SAR problems and suggested solutions

13:00 Lunch

14:15 Case study

14:45 AML/CFT Systems and Controls/ Key Risk Controls

  • Senior Management responsibilities - internal controls
  • The Nominated Officer/Money Laundering reporting Officer
  • Customer Due Diligence (Consumer/Asset/Motor Specific)
  • Staff Awareness and Training Record Keeping
  • The expectations and practice of different Law Enforcement Agencies
  • USA (extra territoriality)
  • Recent cases

15:30 Afternoon tea

15:45 Changes in regime since Dec 2007

  • The Third EU AML Directive
  • Counter-Terrorism Act 2008
  • Statutory Instruments, the hidden menace
  • JMLSG - Directions under the Counter-Terrorism Act 2008
  • JMLSG - Amendments to the Guidance following its August 2008 Consultation
  • The Wolfsberg Group Principles
  • The Treasury Review of the 2007 ML Regs
  • The New UK Supreme Court
  • The Interaction of AML and the 2006 Fraud Act

16:45 Discussions/ questions

17:00 Close

Attached documents