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Unit 9 - Managing the Risk of Money
Laundering and Terrorist Financing
- Money Laundering
- Many different forms
- Property eg. house, car
- Possessions eg. jewelry
- Proceeds of crime eg. drugs money
- Cash eg. theft from
organisation
- Property eg. house, car
- Money laundering is a global phenomenon that
thrives parasitically upon the world’s financial
markets. It often disregards national boundaries
and therefore is a problem that requires both
national and international countermeasures.
- Contributing to the ML
process, however small, is
committing an ML offence
- Money launders: disguise ID, conceal ownership
o property, conceal that they own & control
property, place distance (physical & on paper) in
relation to property.
- The 3 stages
- PLACEMENT: eg. deposit money in a/c
- LAYERING: eg. transactional
stage - move money to other a/cs
- INTEGRATION: eg. 'washed money' now
used within the legitimate economy
- PLACEMENT: eg. deposit money in a/c
- Business awareness
programme for all staff
- Staff vigilance
- Staff understand
legal obligation
- Show why certain
products/services
are vulnerable
- Relevant training to
relevant staff
- Train staff in good CDD
and its importance
- Who the MLRO actually is
- Understand the importance of
AML for business but also
society
- Awareness of policies
and procedures for AML
- Educate staff on
suspicious activity and
how to recognise it
- Staff vigilance
- MLRO role
- Recording & Reporting
on STRs or SARs
- Evaluation of STRs / SARs
- Judge if STR/SAR
requires reporting
to the authorities
- Is the main contact
point for the
authorities
- Be independent
- MI & monitoring
- Awareness of
new ways to ML
- Trend / weakness
analysis
- Recording & Reporting
on STRs or SARs
- Many different forms
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