This is a test course for the compliance team

1. Copyright Valoores all rights reserved: 1989 - 2019
Over 30 years of successful deliveries déjà!
valoores.com
Building a 21st Century Technology Platform
Data Governance - Risk - Compliance - Profitability
AML / CFT Compliance Regime
with our 30+ years of World Wide presence,
International Experience and Discipline,
to serve Locally for a True Business Continuity.
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2. Copyright Valoores all rights reserved: 1989 - 2019
1. Regulatory
• Law for Fighting Money Laundering
• AML/CFT Regulations issued by the Central Bank
• The Special Investigation Commission (a Country’s FIU)
• High Commitment to Compliance
2. Institutional
• Compliance Program
• A designated compliance officer
• A non-going training program
• Independent audit function
VALOORES - Compliance Regime in a Country
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Pillars of the Compliance Regime
Compliance Regime In a Country

3. Copyright Valoores all rights reserved: 1989 - 2019
Law for AML/CFT
• Considered as the cornerstone of the AML/CFT Regime
• Key fundamentals
• Predicate offences
• Reporting Obligation
• Establishment of an FIU
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Pillars of the Compliance Regime - Regulatory
VALOORES - Compliance Regime in a Country
Compliance Regime In a Country

4. Copyright Valoores all rights reserved: 1989 - 2019
The following are some of the fundamental regulations
• Adoption of a Risk Based Approach
• Undertaking Customer Due Diligence
• Verification of Beneficial Owner
• Prohibition of dealing with Shell Banks
• Compliance Program
• Relationship with correspondent banks
• Regulating the “Hawala” system
• Money Service Businesses
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

5. Copyright Valoores all rights reserved: 1989 - 2019
Key Features
1. Risk Based Approach (RBA): Require a RBA to classify customers &
operations into low, medium & high risks (Customer Risks, Country Risks, Service
Risks)
2. Customer Due Diligence (CDD):
• Require clear procedures for opening new accounts
• Require measures for checking customers’ identity and determine purpose &
nature of the account and identify the source of funds
• When CDD cannot be applied in a satisfactory way, No account must be opened
or relation started or operation performed.
3. Verification of Beneficial Owner: Determine Identity of BRO
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

6. Copyright Valoores all rights reserved: 1989 - 2019
Shell Banks
Banks & FIs must ascertain that the respondent bank establishing a
relation with a local Bank or FI:
• Is not a shell bank
• Does not deal with shell banks(Direct/Indirect: Nesting)
• Has good internal controls & implements sufficient and effective
AML/CFT procedures
• Has a good reputation
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

7. Copyright Valoores all rights reserved: 1989 - 2019
Comprehensive Compliance Regime
• Front Liners (Branch manager, AMF/CFT branch officer, cashiers etc.)
• Compliance Department
• Internal Audit Department
• External Audit
• Special Investigation Commission (with country’s FIU)
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VALOORES - Compliance Regime in a Country
Compliance function is not a one person’s job!
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

8. Copyright Valoores all rights reserved: 1989 - 2019
Relationship with Correspondent Banks: Key Features
• Banks & FIs must be fully informed of the laws & regulations governing their
correspondents abroad
• Banks & FI must deal with correspondents in conformity with the laws,
regulations, procedures, sanctions & restrictions adopted by international
legal organizations or by sovereign authorities in the correspondents’ home
countries.
• They must strictly implement AML/CFT regulations by:
• Adopting a RBA
• Vetting the identity of both customers & BRO
• Setting procedures for monitoring operations & accounts on a non-going basis
• Notifying the FIU of any operation contravening this decision
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

9. Copyright Valoores all rights reserved: 1989 - 2019
Hawala System
Only category A exchange institutions are entitled to perform Hawala cash
transfers. They must:
• Notify the Central Bank of their intent to carryout Hawala cash transfers
• Ensure that each Hawala transaction does not exceed an x amount
• Retain for a minimum years period, Hawala records & photocopies of
official documents pertaining to concerned clients
• Establish a compliance department
• Adopt risk-based procedures & measures on Hawala transactions
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

10. Copyright Valoores all rights reserved: 1989 - 2019
Money Service Businesses: Key Features
• Exchange Institutions that undertake cross-border transportation of
cash & precious metals must each:
• Have a capital of no less than x amount
• Appoint an external auditor selected among international audit firms
• Appoint a compliance officer or a compliance unit
• Appoint an Internal Audit Officer
• Exchange Institutions & Banks must provide the Central Bank with a
monthly position for the total cross-border transportation volume,
number & amount of cash / precious metals from / to the Country
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VALOORES - Compliance Regime in a Country
Compliance Regime In a Country
Pillars of the Compliance Regime - Regulatory

11. Copyright Valoores all rights reserved: 1989 - 2019
The Special Investigation Commission is the national central agency for
receiving STRs, is hybrid FIU with judicial character empowered by law to
carry out:
Investigation
• Investigate cases of ML
• Request information from domestic authorities
Supervision
• Supervise Reporting Institutions to ensure their compliance with AML laws
& regulations
Exchange information with foreign counterparts
Freeze
• Accounts / Transactions suspected of concealing ML/TF operations
• Accounts / Transactions suspected to be connected with corruption
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Pillars of the Compliance Regime - The Special Investigation Commission
VALOORES - Compliance Regime in a Country
Compliance Regime In a Country

12. Copyright Valoores all rights reserved: 1989 - 2019
High commitment to compliance is essential on several fronts:
• Political Leadership
• Monetary Authorities
• Financial Sector
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Pillars of the Compliance Regime - High Commitment to Compliance
VALOORES - Compliance Regime in a Country
Compliance Regime In a Country

13. Copyright Valoores all rights reserved: 1989 - 2019
Key Takeaways
• Cyber security is a shared responsibility
• Training/Education is critical
• Basic fundamentals are key
• Focus on both the internal and external
Over 30 years of successful deliveries déjà!
valoores.com
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We bring you the Added Values,
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Compliance Regime In a Country