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The World Bank

The World Bank. Role of Compliance Officers. Mark Butler Financial Sector Specialist, Financial Market Integrity, The World Bank April 19, 2006. Module Overview. - The Compliance Function - Understanding the AML/CFT Framework and Controls - Key Elements of an AML/CFT policy

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The World Bank

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  1. The World Bank Role of Compliance Officers Mark Butler Financial Sector Specialist, Financial Market Integrity, The World Bank April 19, 2006

  2. Module Overview - The Compliance Function - Understanding the AML/CFT Framework and Controls - Key Elements of an AML/CFT policy - Key Operational Controls - Customer Due Diligence - Special Customer Types

  3. Module Overview Cont’d • Identifying Suspicious Transactions and Activities • Internal Reporting of Suspicious Transactions & Activities • External Reporting of Suspicious Transactions & Activities - Cooperating with Authorities - Monitoring and Screening of Customers and Transactions - Record Keeping - Training and Awareness

  4. Responsibilities of the Compliance Officer - Interprets legal and regulatory requirements • Develops AML/CFT bank policy and procedures • Regular review of bank policies and procedures • Provision of advice on potential suspicious transactions and other AML/CFT matters • Monitors compliance with key AML/CFT procedures and controls • Advises senior management on major failures in compliance with AML/CFT policy

  5. Key Elements of an AML/CFT Policy for a Financial Institution • Objectives of the Policy • Scope of the Policy • High Level Summary of Key Controls • Waivers and Exceptions • Operational Controls

  6. Key AML/CFT Operational Controls for a Financial Institution • Statement of Responsibility for AML/CFT Compliance • Risk Management Practices • Customer Due Diligence • Monitoring for Suspicious Activity • Reporting of Suspicious Activity • Cooperation with Authorities • Record-Keeping • Screening of Transactions and Customers • Training and Awareness

  7. Risk Management Approach Adopting Risk Based Approach • Geographical Factors • Customer Types • Product Type Risk Management • Controls • Benefits to the Organization • Customer Service • Protection from Risk

  8. Customer Due Diligence Policy - Customer Identification / Verification • Additional Know-Your-Customer Information • High Risk Customers • Non Face to Face Business • Correspondent Banking • Handling of Politically Exposed Persons

  9. Customer Due Diligence Policy Identifying and Verifying Customers • Personal Customers • Identity • Address • Other Personal Details • Details of account activity expected

  10. Customer Due Diligence Policy Identifying and Verifying Customers • Corporate Customers • Confirming Existence of Company • Identifying and Verifying signatories • Identifying and Verifying directors • Identifying major shareholders and beneficial ownership • Details of the business conducted & account activity expected

  11. Customer Due Diligence Policy Special Customer Types • Correspondent Accounts • Non Face-to-Face Customers • Politically Exposed Persons • Intermediaries • Other High Risk Customers

  12. AML/CFT Operational Controls Identifying Suspicious Transactions • Frontline Staff • Customer Activities • Management (Exception) Reports • Compliance Unit • Computerized Monitoring Systems

  13. AML/CFT Operational Controls Reporting Suspicious Transactions • Procedures • Responsibilities • Format of the Reporting Form • Dealing with Customer After Reporting

  14. AML/CFT Operational Controls Monitoring & Screening of Customers • Issuance of Lists • Name matching • Wire Transfers

  15. AML/CFT Operational Controls Record Keeping • What records should be kept? • How should they be kept? • For how long should they be kept?

  16. AML/CFT Operational Controls Training Awareness • What staff should be trained? • What should they be taught? • How can they be taught? • How often should training be given?

  17. AML/CFT Issues for Compliance Officers External Reporting • Suspicious Transaction Reports • Consent needed to continue the transaction / account • Provision of further information • Currency Transaction Reporting (if applicable)

  18. AML/CFT Issues for Compliance Officers Cooperation With The Authorities • Confidentiality Issue • Provision of further information

  19. The World Bank Role of Compliance Officers Mark Butler Financial Sector Specialist, Financial Market Integrity, The World Bank April 19, 2006

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