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ANTI-MONEY LAUNDERING AND COUNTER TERRORIST FINANCING
KNOW YOUR CUSTOMER (KYC)
– consult on Customer Relationship Management software, transaction monitoring solution, customer on-boarding service provider, etc.;
– build KYC program and procedures;
– create customer-friendly KYC questionnaire.
KYC or Customer Due Diligence is not only about the identification and verification of your customer’s identity. It is also a process during which you get to know your client better by collecting such information as residential address, contact details, the purpose of the account with your organization, etc. If you provide services to business clients, you definitely want to know your customer‘s ownership structure, economic activity, source of funds, etc.
Usually, financial institutions create KYC questionnaires to collect all the necessary data. Then follows the process of information verification, customer screening and risk scoring.
Effective Know Your Customer Compliance
KYC is a continuous process – the information you collect during customer on-boarding has to be reviewed and, if necessary, updated. What is more, you also have to monitor your customer’s activity in order to assess whether it is in line with the information collected at the beginning of the business relationship.
To design a flawless and effective KYC process, you have to:
– decide on-boarding method: remote or face-to-face;
– create a customer-friendly KYC questionnaire;
– introduce convenient Customer Relationship Management software;
– build information storing solution;
– set up transaction monitoring;
– design ongoing due diligence process.
We can assist in:
– giving introductory, refresh or specific training to all level of your employees on AML / CTF topic;
– creating training program;
– setting up record-keeping process.
Due to increasing regulatory requirements, new money laundering and terrorist financing trends the financial institutions have to look for the ways how to keep up with the fast-changing environment. Therefore, it is crucial to give proper training to people who join your company.
It is worth mentioning that every employee of the company has to go through the AML compliance training and sometimes it might be challenging to adapt the material to specific needs. It is not enough to simply give introductory training to everyone, especially to the AML compliance personnel.
Requirements for Anti-Money Laundering Training
When designing your training program, you should think of the following:
– when and how the training will be delivered;
– whether external training will be needed;
– how knowledge after the training will be assessed;
– how you will keep records and store training material;
– when a re-fresh will be needed.
Training should be a continuous process so that your employees are up-to-date with the latest regulatory or any internal operational changes, are aware of such things as tipping off and know what to do when customer’s actions raise suspicions.
INTERNAL POLICIES, PROCEDURES AND CONTROLS
– draft internal policies, procedures and design controls;
– review and improve existing policies, procedures and controls.
It is great when your employees know what to do but in order to achieve effectiveness and reduce the number of mistakes it is important to have written internal policies, procedures and establish controls. When you have written procedures, your employees can consult them any time to successfully complete their daily tasks. It is also a way to set the minimum standards and leave as little space for interpretations as possible.
The Main Principles for Creating of Internal AML Policies, Procedures
When creating your internal policies, procedures and controls, you should think of:
– simplicity – documentation needs to reflect your action rather than repeat AML law;
– clarity – do not use over-complicated words or structures;
– purpose – what do you want to achieve with the procedure;
– audience – who should follow this procedure;
– timing – when, what and to whom reports should be provided.