Indicate to the authorities that you have fulfilled your regulatory duty by referring the matter to them
Inform the customer that his/her activity has been reported as suspicious and the authorities are asking about him/her
Cooperate fully with the authorities, as permitted by law.
Give the authorities everything they request.
Report on the level of monitoring performed on the activity in the accounts.
Report by each country’s compliance with the legal requirements within their country
Report on compliance with each country’s requirements only for those customers that are serviced by branches in multiple countries; all others should be reported on the company’s stated requirements
Report on compliance with the company’s stated requirements.
By having auditors conduct testing on employee compliance
By having the AML officer personally tell associates of their responsibilities.
By having senior management require compliance as a condition of employment.
By pointing out the regulatory consequences of non- compliance in training
Name, legal form, status and proof of incorporation of the legal person
Identity of natural persons who have authority to operate the account and who exercise control of the legal person through ownership or other means.
A report describing a visit, by the account officer, to the principal place of business.
Permanent address of principal place of the legal person’s activities
Customer due diligence error rates, quality assurance testing on STR filings, percentage of products and services monitored for suspicious activity.
Sales staff surveys on AML efforts, customer due diligence error rates, quality assurance testing on STR filings
Quality assurance testing on STR filings, sales staff surveys on AML efforts, percentage of products and services monitored for suspicious activity.
Customer due diligence error rates, sales staff surveys on AML efforts, percent of products and services monitored for suspicious activity
Consult with the regulators, provide training to impacted associates and work with the technology partners to capture all cross-border transactions for reporting
Implement a testing plan to be sure appropriate transactions are captured and reported, provide training to impacted associates and consult with the regulators.
Work with technology partners to capture all cross- border transactions for reporting, implement a testing plan to be sure appropriate transactions are captured and consult with the regulators
Provide training to impacted associates, work with technology partners to capture all cross-borders transaction for reporting and implement a testing plan to be sure appropriate transactions are captured and reported.
Whether the training was provided to the board of directors
The names and areas of the employees who took the training.
The topics the training addressed
Whether the employees who took the training passed the post-training assessment.
The inherent risk of the product, the control environment to mitigate the risks presented by the product, the residual risk of the product in light of the controls.
The projected profitability of the product, the control environment to mitigate the risks presented by the product and the Inherent risk of the product
The residual risk of the product in light of the controls, the inherent risk of the product and the projected profitability of the product.
The control environment to mitigate the risks presented by the product, the residual risk of the product in light of the controls and the projected profitability of the product
Implement a process to determine when new regulations are published and assess them for impacts to the AML program.
Conduct a risk assessment to determine if the regulations change frequently enough to implement a process to check for changes.
Request permission to attend future annual AML- industry conferences
Ask internal auditors to provide her with notice of changes needed to the program
Provide a summary of all reported suspicious activity
Rely on the internal audit reporting and regulatory examinations
Provide detailed training to senior management on their AML obligations.
Develop a report containing metrics that reflect the effectiveness of various key program elements.
Let the independent audit function remediate the issue, as they have identified it and the resolution of the issue needs to be handled independently of the compliance function
Escalate the matter to the account opening team and have them make the appropriate business decision.
Dispute the finding with audit, as the compliance officer should be sufficiently empowered to make all AML-related decisions for the institution
Develop and follow an action plan to remediate the issue and report to audit on the progress made on the issue.
Money Laundering and Confiscation
Powers and Responsibilities of Competent Authorities and Other Instructional Measures.
Financial and Non-Financial Institution Preventative Measures
Contact the Board of Directors as soon as possible and inform them of this activity
Immediately contact law enforcement by phone and tell them of the potential money laundering activity
Make a note of the activity, but do not file a STR in order to not risk losing a longtime customer.
Collect the appropriate documentation and review it with the purpose of filing an STR.
An agreement between two parties establishing a set of principles that govern their relationship on a particular matter. An MOU is often used by countries to govern their sharing of assets in international asset-forfeiture cases or to set out their respective duties in anti-money laundering initiatives.
An agreement among countries allowing for mutual assistance in legal proceedings and access to documents and witnesses and other legal and judicial resources in the respective countries, in private sectors, for use in official investigations and prosecutions.
A written request for legal or judicial assistance sent by the central authority of one country to the central authority of another when seeking assistance from the foreign jurisdiction
The officer should confer with bank counsel as to whether to request subpoenas from law enforcement
The officer should allow the employees to be interviewed only if they are given immunity by law enforcement.
The officer should only allow those employees who are comfortable be interviewed by law enforcement
The officer should deny permission for any such interviews without the creation of a grand jury or a formal court ordered investigation
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