Regulators around the world are increasingly recognising the importance of ensuring that their banks have adequate controls and procedures in place for Anti-Money Laundering and the Combating Finance of Terrorism.
With many institutions now operating in multiple jurisdictions and as a matter of policy, these offices must comply with both local laws and regulations and recognized best industry practices. This is essential if the organization is to safeguard its reputation and good name wherever it operates.
GSA AML/CFT policies and procedures are based on recommendations developed by FATF on money laundering, terrorist financing & corruption together with international initiatives such as Basel Committee Papers, Wolfsburg Initiatives/Principles, UN Regulations and IMF & World Bank Guidelines and UK FSA Guidelines.
The core components of most AML Programs includes:
- Customer Identification / Know Your Customer (KYC)
- Enhanced Customer Due Diligence (ECDD)
- Know Your Employee (KYE) / Employment Screening
- Ongoing Customer Due Diligence (OCDD)
- Transaction Monitoring Program (TMP)
- Board and Senior Management Oversight
- Independent Review
- Staff Awareness Training
- AML Programs and Policy
Monitoring & Reporting
The problem of laundering of the proceeds of criminal activity is worldwide. Financial institutions are particularly at risk of being used, even unwittingly, to launder money. Consequently, in many jurisdictions, financial institutions are under a statutory obligation, via FATF guidance, to establish and maintain procedures designed to prevent money laundering and report suspicious transactions to the competent authorities.
The Unusual is NOT the same as the Suspicious
Unusual transactions do not of themselves constitute grounds for suspicion and therefore should not be the routine basis for making reports to the Competent Authorities.
However, unusual transactions will often be the one that is inconsistent with the customer's known legitimate business or personal activities or with the normal business for that type of customer.
GSA provides organizations clear procedures for account and transaction monitoring and for the reporting of suspicious activities.