How to create a Compliance Program ?

A Compliance Program (CP) is a manual that contains the internal policies and procedures of a listed business. The Know Your Customer (KYC) forms are attached as appendices to the compliance program.

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What are the key elements of a Compliance Program?

The staring point is that there must be a risk based approach in the Anti-Money Laundering (AML) Compliance Program.

The four (4) pillars of an effective Anti-Money Laundering (AML) Compliance Program are:

  1. The development of internal policies, procedures, and related controls;
  2. The designation of a competent and qualified Compliance Officer;
  3. Ongoing AML training for all staff, directors of the listed business;
  4. Independent review of the Compliance Framework by a competent and qualified AML auditor.

Yes we create Compliance Programs!!

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through  Paywise or Paypal

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company.

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What is Wire Stripping? Free AML Training

Money launderers use wire transfers daily to move dirty cash between countries and bank accounts[1]. They also use wire transfers to distance illegal funds from their original source.  The objective is to move the dirty money from one bank account to another and from one jurisdiction to another. This makes it difficult for Law Enforcement Agencies (LEA) to trace the origin of the money.

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In executing their correspondent banking services and daily payment operation banks are now exposed to wire stripping which impacts on cross-border banking activity. The failure on the part of Financial Institutions (FI) to monitor or prevent wire stripping will render FIs unable to screen and stop payments to designated entities and individuals[2].

Wire Stripping defined

It is the deliberate act of changing or removing material information from wire payments or instructions, thus making it difficult if not impossible to identify and restrict payments to and from sanctioned individuals, entities or countries.

How is it done

FIs may conceal or simply removing true originators from transactions processed through US banks in order to avoid the sanctions-monitoring programs put in place by those institutions. The FI may weed out, tamper, or even alter the payment details of the transfer with respect to[3]:

-the ordering client;

-The beneficiary client details such as (country, address, name);

-the origin of goods and

-sea ports involved.

Some FIs even advised originating banks on how to format their transfers in a manner that would allow the transactions to avoid detection completely[4].

Result

These FIs were subjected to regulatory fines and suffered irreparable reputational damage.

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

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Sources


[1] https://www.riskscreen.com/kyc360/article/implementing-sanctions-screening-and-due-diligence-methods-for-products-and-payments/

[2] https://www.ey.com/Publication/vwLUAssets/Understanding_sanctions:_wire_stripping_-_managing_compliance_risk/%24File/1308-1124709_Wire%20Stripping%20.pdf

[3] https://www.riskscreen.com/kyc360/article/implementing-sanctions-screening-and-due-diligence-methods-for-products-and-payments/

[4] https://www.ey.com/Publication/vwLUAssets/Understanding_sanctions:_wire_stripping_-_managing_compliance_risk/%24File/1308-1124709_Wire%20Stripping%20.pdf

What are Shell Companies ?

A shell company is considered to be an incorporated company with no independent operations, significant assets, ongoing business activities, or employees. Shell companies tend to be…holding companies.[1]

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To launder money, the shell company purports to perform some service that would reasonably require its customers to often pay with cash.

The launderer then deposits the money with the shell company, which deposits it into its business bank accounts. The company then creates fake invoices and receipts to account for the cash. Such transactions create the appearance of legitimacy and clean money.

The shell company can then make withdrawals and either return the money to the initial criminal or pass the money on to further shell companies before returning it to further disguise who initially deposited the money[2].


[1] https://aml-cft.net/library/shell-company/

[2] https://www.law.cornell.edu/wex/money_laundering

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

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THE ROLE OF A COMPLIANCE OFFICER

The Compliance Officer is the primary liaison with the FIU . The identities of the Compliance and Alternate Compliance Officers must be held with the strictest confidence.

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The duties of the Compliance Officer include:

a)Creating, monitoring and updating the AML/CFT Compliance Programme to ensure continuous compliance with the legal framework. The internal controls and policies therein must be implemented by the CO.

b)Receiving and assessing SAR/STR reports made by staff members.

c) Reporting SARs/STRs to the FIU using the Suspicious Activity/Transaction Report Form within fourteen (14) days of the suspicious transaction being detection.

d)Maintaining records of internal SARs/STRs from staff.

 e)Maintaining a register of of SARs/STRs filed with the FIU.

f)Maintaining Customer Due Diligence records and transactions;

g) Monitoring the FATF list of high risk individuals and legal entities and Non-Cooperative Countries and Territories (NCCTs).

h)Monitoring the United Nations ISIL Da’esh & Al Qaida List (UN 2253 List) for persons identified as terrorists or involved in terrorist activity.

  i)Provide training to all members of staff.

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

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How to do a Cash Flow Statement ?

There are 2 important aspects of a Cash Flow Projection:

1.An estimation of the total income that the business will receive in 1 month;

2.An estimation of all the expenses incurred by the business in 1 month.

For assistance with Cash Flow projections call Sydney 868 373-1166

Income

In order to determine the income that your business generates, you should be keeping a great record of all the money that you receive. It can be as simple as having a receipt book or using an excel sheet to list the amount of money earned. It can be more sophisticated by using accounting software or an application on your phone. As a business owner you must keep track of all the cash earned in order to determine how to make improvements to ensure that the business is sustainable.

For assistance with Cash Flow projections call Sydney 868 373-1166

Expenses

You should also have a well maintained record of the money that you are spending to further the business. You may keep a folder to store all receipts and log the respective sums in it. You may find that some expenses are fixed and are incurred monthly. Some examples of expenses are travelling expenses, raw materials.

For assistance with Cash Flow projections call Sydney 868 373-1166

You will basically subtract your expenses from your income to show whether the business is making a profit or a loss.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

The author is an attorney at law based in Trinidad and Tobago. Please see: http://asydneygroup.com 

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AMNESTY FROM PENALTIES FOR LIMITED LIABILITY COMPANIES

You have one more month to take advantage of the Amnesty from Penalties from the Registrar’s General Department for outstanding documents in Trinidad and Tobago.

The Amnesty took effect from Wednesday May 1st 2019 and will end Wednesday 31st August 2019.

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Take advantage of this chance to file:

I)Outstanding Annual Returns under Section 194 of the Companies Act (1995).

II)Notice of Secretary/Assistant Secretary (ies) or Change thereof under Section 178 of the Companies Act (1995);

III)Notice of Change of Directors or Change thereof under Section 79 of Companies Act (1995);

IV)Notice of Change of Address or Change thereof under Section 176 (2) of Companies Act (1995)

V)Notice of Execution or Termination of unanimous shareholder agreement under Section 137 (4) of Companies Act (1995)

After the amnesty, the penalty of $300.00 TTD per month WILL BE INCURRED.

Call OR Whatsapp us , Give us the name of your Company, Sign and Pay…WE DO THE REST !!

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company;

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What does CU mean: AML Compliance Consultants

CU is an acronym for Credit Union. Credit Unions are governed by the Central Bank of Trinidad and Tobago as well as the Financial Intelligence Unit (FIU).

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The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company.

#amlcomplianceconsultant #trinidadonlinelawyer #asydneygroup.com #businessregistration #antoinettesydney #sydneygroup #asydneygroup #trinidad #company #companies #lawyer #caribbean #aml #fiu #cft #frm #fraudrisk #graphicdesign #tax #taxation #taxes #nis #vat #bir #fiu #compliance #complianceofficer #realestate #casinos #cardealer

What is CFATF?: AML Compliance Consultants

CFATF-this is an acronym for Caribbean Financial Action Task Force.

Check my Youtube Channel for more:

The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company.

#amlcomplianceconsultant #trinidadonlinelawyer #asydneygroup.com #businessregistration #antoinettesydney #sydneygroup #asydneygroup #trinidad #company #companies #lawyer #caribbean #aml #fiu #cft #frm #fraudrisk #graphicdesign #tax #taxation #taxes #nis #vat #bir #fiu #compliance #complianceofficer #realestate #casinos #cardealer

What is SOW?: AML Compliance Consultants

SOW is an acronym for Source of Wealth. Source of Wealth refers to the origin and the activity that generated your entire body of wealth. As distinct from Source of Funds that is concerned with the funds used for the particular transaction.

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The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company.

#amlcomplianceconsultant #trinidadonlinelawyer #asydneygroup.com #businessregistration #antoinettesydney #sydneygroup #asydneygroup #trinidad #company #companies #lawyer #caribbean #aml #fiu #cft #frm #fraudrisk #graphicdesign #tax #taxation #taxes #nis #vat #bir #fiu #compliance #complianceofficer #realestate #casinos #cardealer

What does ATA mean? AML Compliance Consultants

The acronym “ATA” stands for the “Anti-Terrorism Act”. This Act criminalizes terrorism and allows for the detection, prevention, prosecution, conviction and punishment of terrorist acts, the financing of terrorism, forfeiture and seizure of terrorists’ assets.

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The author is the first Online Lawyer based in Trinidad and Tobago. She specialises in Anti-Money Laundering Compliance.

Website: www.asydneygroup.com

Call/Whatsapp for a quotation 868 373-1166

Services include:

Anti-Money Laundering (AML) Training for staff, directors;

Anti-Money Laundering Audits;

Compliance Program drafting;

Consulting services and much more.

Ebooks available for only $100TTD !

Payment through Paywise and Paypal!

Ebooks on Sale:

How to Register a Sole Trader;

How to De-Register a Sole Trader;

How to Register a Partnership;

How to Change from a Sole Trader to a Limited Liability Company Trinidad;

How to Dissolve a Limited Liability Company.

#amlcomplianceconsultant #trinidadonlinelawyer #asydneygroup.com #businessregistration #antoinettesydney #sydneygroup #asydneygroup #trinidad #company #companies #lawyer #caribbean #aml #fiu #cft #frm #fraudrisk #graphicdesign #tax #taxation #taxes #nis #vat #bir #fiu #compliance #complianceofficer #realestate #casinos #cardealer