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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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.

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How to Register with the Financial Intelligence Unit (FIU) in Trinidad?AML Compliance Consultants

What is the FIU?

The FIU is the  primary institution for the collection of financial intelligence and information and the analysis, dissemination, and exchange of such financial intelligence this will also include information among law enforcement authorities, financial institution and listed businesses


Which businesses are required to register with the FIU?

Non Regulated Financial Institutions[3]

  • Credit Union
  • Building Society
  • Money or Value Transfer Services

Listed Businesses[4]

  •  Motor Vehicle Sales
  • Real Estate
  • Gaming House
  • Pool Betting
  • National Lotteries On-Line Betting Games
  • Jeweler
  • A Private Members’ Club
  •  An Art Dealer
  • An Accountant, an Attorney-at-law or other Independent Legal Professional
  • Trust and Company Service Providers 

The FIU Form RG 1 must be printed from the FIU website and completed. This form must be submitted to the office of the Financial Intelligence Unit within three months of the registration of the company or business. Within 14 days the FIU will confirm receipt of your registration documents by email or phone call. The FIU will indicate whether your certificate is ready for collection.

What is the penalty for failing to register with the FIU?


What is the penalty for failing to register with the FIU?

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The author is the first Online Lawyer  based in Trinidad and Tobago. She specializes in Corporate Law and Financial Crimes.

Request a quotation: 868 373-1166

Website: http://asydneygroup.com

Services: AML Audits;

AML Compliance Program;

AML Training;

Consulting

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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[1]http://www.investopedia.com/terms/a/aml.asp

]http://www.fiu.gov.tt/about_fiu.php?mid=3

3]http://www.fiu.gov.tt/about_fiu.php?mid=4

[4]http://www.fiu.gov.tt/about_fiu.php?mid=4

What does the Financing of Terrorism mean?: AML Compliance Consultants

The funding of terrorism involves providing funds from both legal (personal donations and profits from businesses and charitable organizations ) and or illegal sources (the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion), directly or indirectly or knowing that the monies are to be used to finance terrorism activity or organizations according to FINTRAC.

It follows that Countering the Financing of Terrorism refers to all the efforts to counter this.

Please Whatsapp 868 373-1166 for all your Anti-Money Laundering Compliance needs.

Website: http://asydneygroup.com

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

She is a Certified Professional in the following areas:

Anti-Money Laundering and Financial Crimes;

Taxation;

Corporate Training;

Fraud Risk Management;

Graphic Design.

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SOF Defined!! AML Compliance Consultants

SOF is an acronym for Source of Funds. Source of funds refers to the origin of the particular funds or other assets which are the subject of the business relationship between the client and the financial institution or listed business. (e.g., the amounts being invested, deposited, or wired as part of the business relationship).

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

Website: http://asydneygroup.com

She is a Certified Professional in the following areas:

Anti-Money Laundering and Financial Crimes;

Taxation;

Corporate Training;

Fraud Risk Management;

Graphic Design.

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

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

What is an AML Compliance Officer?AML Compliance Consultants

This is someone with a background in law, finance, management, insurance, accounting who will ensure that your company follows all the laws and regulations with respect to anti money laundering .

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Ebooks available for only $100TTD !

Payment through Wipay 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.

The author is the first Online Lawyer based in Trinidad and Tobago. I She specializes in Corporate Law and Financial Crimes.

She is a Certified Professional in the following areas:

Taxation;

Corporate Training;

Anti-Money Laundering and Financial Crimes;

Fraud Risk Management;

Graphic Design.

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What is CFT? :Countering the Financing of Terrorism:AML Compliance Consultants

What is Terrorism?
Terrorism is the calculated, premeditated use of unlawful violence to cause panic or advance a political, religious, ideological cause.

Financing of Terrorism
Funding of terrorism involves providing funds from both legal (personal donations and profits from businesses and charitable organizations ) and or illegal sources (the drug trade, the smuggling of weapons and other goods, fraud, kidnapping and extortion), directly or indirectly or knowing that the monies are to be used to finance terrorism activity or organizations according to FINTRAC.

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Terrorism is financed in order to:
Promote militant ideology;
Purchase food for recruits;
Purchase weapons;
Pay operatives;
Arrange for travel;
Train new recruits;
Forge documents;
Pay bribes;
Acquire land;
Stage attacks.

How to proceed when it is discovered that a potential or existing customer is a terrorist ?
As soon as a financial institution or listed business receives the list of designated entities or the consolidated list referred to in section 22AA(2)(c) or (e), the following procedures shall apply:
(a) the financial institution shall immediately inform the FIU on the prescribed form, if any person or entity named on either list has funds with the financial institution or listed business;
(b) if the financial institution or listed business has reasonable grounds to believe that a person or entity named on either list has funds in Trinidad and Tobago, it shall immediately inform the FIU on the prescribed form;
(c) (Deleted by Act No. 14 of 2012); and
(d) if a person or entity named on that list attempts to enter into a transaction or continue a business relationship, the financial institution or listed business shall submit a suspicious activity report to the FIU immediately and shall not enter into or continue a business transaction or business relationship with such person or entity.

The law requires that the transaction and by extension, the business relationship be brought to an end and a Suspicious Activity/Transaction Reported be submitted by the Compliance Officer to the FIU.

See
Anti Terrorism Act of Trinidad and Tobago,PART III FINANCING OF TERRORISM 22AB

The author is an attorney at law in Trinidad. She specialises in Anti Money Laundering and Financial Crimes. Website http://asydneygroup.com

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