Money Laundering Regulations - Mitigating Risk

Hi, My name is Rachel Coyle. I'm embarrassed with six. Great. And I have to say in the 36 able Team today, no rent. You talking about new regulations? Mainly the money laundering. Tired financing on transfer informs information on the pair. Regulations 2017. Referring to these. Ask the regulations These transpose the fourth e money laundering director until you can. No, he's any regulations commenced on 26 year 2017. No doubt it will be a great benefit to be aware of the differences between the old regulations in 2007. I'm pleased the recommendations and Robson subtle differences, but you need to be aware. The first is about risk assessment. Certain regulation. Regulation 18. One way firm has to conduct a money laundering and terrorist financing Gross assessment. Now there are things that you have to consider when you do this. Lastly, the customers. Secondly, the country, the geographic areas where an individual business operates 38 types of products and services, mostly transactions perfectly good. Every channel things you should consider. But this is by no means he's hosted Miss all these. Would you have a high client turnover? What do you have a stable crime face. Well, you have a client based in jurisdictions where there is perhaps a higher risk of money laundering. Were indeed tires finals. Whether you have quiets who operate in sectors that by their nature pose a higher risk of 100 whether on how often e acts for political exposed persons applies now PDP's whether and how often you actually clients without eating them. Finally, tactic work took them were organization takes generally. Now this is by no means exhaustive list. But they have certainly things to consider when you are putting together more risk assessment either individual or group of individuals company business, they're not prerequisites. But they call recommended, and you will see the doctor found the draft regulations in March 2070 that well, in the guidance that was set out also in consultation paper. So, having you implement these new regulations, what is it that you have GOP senator? Well, the first is you need to have assistance, policies, controls and procedures. That sounds like a lot of jog. And I know what I try and write it down for you. When you have a consistent policies, have to reflect these new regulations that would be proportionate to the size and nature of your business that happen. Regularly reviewed and updated, you communicated to all staff on a full member of your organization, but internally and even if they do basis externally, so what? Almost these policies and procedures cover well, it has to cover the risk management practice. So, for example, the risk assessment that you walked home place circulation it must emphasize the controls. You have a doctors okay, in accordance with regulation 21 to 24 in 2017. Regulations. How you conduct customer due diligence channel comes extraordinaire. You're reporting in control systems. Your record keeping. How do you want it? How do you cross to be checked, monitoring internally and communicating, managing compliance with your homes qualities, controls, procedures, identification as scrutiny or complex and perhaps unusually large, unusual patterns of transactions that have happened. No economic when you compare this on other activities that you think are likely related to money laundering. Well, Charles Finance, perhaps taking additional measures where appropriate to prevent more than ordering or terrace found incision in relation to parts of toes is that favor community? Take appropriate steps to besets. I didn't necessarily mitigate the risk off money laundering and terrorist climaxing when you doctor new technology and finally making of disclosures on the par three off Turn it about 2000 cops, seven of the proceeds of crime in 2002. Now there's a two rather separate areas that I want. Seeks discussed today would ultimately. What that means is that there are disclosure. You have to disclose information. You find something that is all towards either to the state of national security or interviewed. This reaches a lot. I could any transaction, but with that, it is perhaps a little bit more about Susan. Involved terrorism. Deep proceeds of crime. Did you have any doubt You need to have policies and sidewalks. Your staff are dio when they do these tracks, should they find must be the case. Secondly, how else can you have these regulations? Well, you can apply policies, procedures and controls across the entire group structure. It's not just my perspective teams, you know, if you have one too you might deal with. For example, I mean private individuals. You have another to any deals with commercial businesses. They still have to comply with the same policy, the same calls. You should be applied across the board. And it also means that I believe any doubt whatsoever. Especially you have a lot of high staff turn organization, not the case. This is a case that a BSS domesticate for any organization, but that's past any dealing with finance. Um, and the services provided so it turns, tried to apply up to structure those policies that risk assessment. How conventionally do that? Well, if I say, is to adopt appropriate internal control, for example, you can't wait. A person at the level off board of directors, have equipments off management body or to use the term senior management to be responsible for compliance with regulations. Second Harriott Screening Government employees PARIS That appointment on drink a quart of airplane without is on the board of directors, management or duty. Even very, you're actually going to be doing compliance trapped in Danish jacks that time able to screen. Certainly you need to establish a department auction examining, evaluates, make recommendations about the antiquity of your policies and control. Now this company and turtle. But in order to win any doubt whatsoever once neutrality. I suggest that next order it is done on a regular basis to ensure that policies will comply to ensure that only Lord regulations have been halted. Force people properly. Organization required to appoint responsible compliance with the regulations is additional to your obligations to appoint an hour around. And they see out pay you the same kind of hole it might be that you are going to take some level off screening duration to your staff. We need to ensure that this inclusion your assessment off their skills than knowledge that tease to carry out the commission's effectively on assessment of that conduct integrity. It might even have to have continually you often individual or a team of people to ensure that that compliance is followed. Florida The regulation is do your state. That independent order function I mentioned previously have to be so external. But as I have indicated interest in ensuring child would be beneficial, you must also ensure that to establish and maintain a system that allows you to respond fully and rapidly to enquiring from Laura, forceful as to whether you have had a business relationship with a person or organization in the last five years. I'm in nature. That relationship don't try to force to construct. Tried, undoubtedly, compression privilege would never liked. You must have a system in place where assuring that you could do with those required very quickly, very probably the reason may not. So because UK to choose why such acquires being life. But nevertheless we'll have a visa regulations. There's no need you to be concerned to. One of our Coulson is coming to you for information. So how last commonly applied policy procedures across the group structure? Second things really trying to stop one of things that people is assessment. I'm sure that they understand what diligence means, which means we find that stop it diligence. There are essentially three types of diligence applicable 29 regulations that first is customer due diligence. The second is enhanced due diligence on the third is simplified due diligence. Now we're just going to go through each of the letters in time. The first is that course mature dodges one of the regulations you are required to more identifying client very violent identity on the basis of reliable independent source of Charles Hospital. I was a day where applicable. I've identified. Beneficial owners of the client take reasonable measures to verify their identity, so you know who they are. But if the beneficial owner is an entity or legal arrangement, take reasonable measures to understand its original I'm control structure actually assessed where progress obtain information on her on intelligent nature off business relations transaction. It sounds so straightforward to something probably really doing. But now I need to have a pet travel according, and it's easy to to always get to do these things when it might be client you lived out with all the intel that hot basis for why I know quite well on it might also be that you are just simply too busy but maintaining pain trial, ensuring the checks don't know absolutely the crucial, because these money loans, regulations all extremely owners, yes, but all that designed to forage, you know, ordering, obviously waiting. Also yourself called out that much. You know that he can shake down everything you can that can't be accused of being complicit. Clyde And then finally, when it closed to cost due diligence, identify, verify the identity of the person who reports, acts on behalf of clients and very there all right to act. Well, we know passport is No, no, you have to go to stop. It's a corporate body. Then you must not tell you. Verify name all the corporate body is company already of registration. I was the address is registered office and did his principal place of business. In addition, yeah, the corporate body competently that is not listed on a regulated market. He was taken even more reasonable measures to tighten very far. Personally, the law which to subject its Constitution or any other documents on secondly, remains off. The board of directors will equivalent one body on the senior person responsible for its operations. We're not sure that is cost Majeed origins. It sounds like there's not really much to it. What's quality regulations are concerned. It goes beyond just looking past, you know, have to verify that person is passports in over on its side looking out and hunts due diligence under Regulation 33 Subsection one. This does set out a list of circumstances in which to put it in short, e d. D. Actually, judges measures must be applied, which includes any transaction or restoration involving a person established high risk the country and transaction oppressed alleged involving prickly person okay or a family member notice Social. Typically, ECRI on any other situation presents a higher risk of money laundering or terrorist. Now the list is quite long, but that is where you will find the list of circumstances in which those measures must be applied. Were there not sure those are principle our most important relationship that you have to consider every time you have an individual organization or body. You also need to consult Regulation 33 subsection six. This sets out list does that must be taken to account in assessing whether there's a higher risk of money laundering and terrorist finals present in a given situation. On the extent of those measures that should be applied again, it is quite another left with those. The fact that you have to and it could be got back was included in any policy. What part of your risk assessment with individuals or corporations very simplified you diligence belies that existed. Simplified due diligence is permitted. Were you determined that business relationship or transaction present a low risk of money laundering or terrorist relationship or terrorist financing? Tell you to count. Of course, the risk assessment lead we discussed earlier. Regulation 73 sets out a list of factors get into taking into account. I did tell you when you're not situation posts with lower risk of money laundering or terrorist financing such that STD measures coming applied so called sturgeon to go costly due diligence, house due diligence and simplified you Georgians, you will need to monitor, which is those almost ready to give in case. But you have to actually paper trail off that you essentially politics clearly sets out a sign host walk us a. New Georgians is what that involves. What factors that I just completely here and likewise have studio agents and simplify to religions the fact of a very tight regulations. They are, you know, those really to have the final two topics is the political. It's both persons now not great. Deal has changed about this, but just civilized. What new regulations state If you have a situation with a he paid this person or, um about closest station for people that he was out a minimum of three things personally. How senior my crew establishing continuing that business relationship. Second take adequate measures to establish this source of wealth on saxophones Bold in the restoration transaction. They conduct enhanced ongoing monitoring off this relationship. And you might have to explain that to your hey on it might be that might do so because it makes it look like I don't trust them. But if you explain to them the reason for doing that and that is that you're bound by Or perhaps you would understand, because obviously we all appreciate you understand what to retain clients where possible. But that doesn't mean they have to be aware or what more obligations are legally speaking out again. Just to remind you, P P is defined in the regulations, You now find it a regulation 35 subsection 12. On On like that, you have seven regulations. Listen, please. For you carry P find leaves and record keeping. You must ensure that your record data protection systems policy procedures meet requirements of regulation regulation forcing. You must keep a copy documents and information off time to spell your cost. Maji dungeons obligation. Did Waterman tell about you can pay betrayal by which I mean a try. But if you do get that like they have to be corrected usual where presented again. Great protection. And what these obligations on paper charge demonstrate is that you have supporting records to show you have done what we're supposed to do with regulations. And there will be no question, hopefully as to what actions you have taken to drinking compliant. So if I mean I think those crop up until eight a diet there's no doubt that you did everything that you could with in compliance with the regulations. Without a paper trail without any electronic records, you have a very courts pretty done. What needs to be done in terms of how time to keep your records for the records of any transaction, for example, should be kept for a least a period of five years. Language he If there is no continued of a situation, you command displays of backwards in the usual. When I actually have any day to protected, data attracted documentation, but otherwise it's extenuation or travel action helping their complaints. They are as long as that that is live. Then we'll have to maintain and keep those documents until whenever that period finishes. No fighting. After that, I have no further parts of regulation. I feel it necessary to bring to attention part of those today. If you would like for him to make on any part of regulations, in particular honors and discuss today already, you probably feel like you need to dress. Please do not hesitate to contact me directly through my clocks at this. No, if you could please have a look at the violation for Have a look at those questions. Have a go at that and hopefully we have learnt enough to be able to help those questions. You can ask those questions and hopefully we'll have taken a while. I answer on her to be extremely beneficial. T thank you very much.