WEBVTT

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Welcome to our corporate Anti Money Laundering training session. This

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video is part of your mandatory employee onboarding.

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Our company is required by the regulatory framework to put in place

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checks to prevent the facilitation of movement of illegal

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transactions.

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All employees must familiarize themselves with the process of money

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laundering, which the criminal businesses use to disguise the true

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origin and ownership of illegal cash.

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Money laundering is the process of making illegally-gained proceeds

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appear legal. Criminals use money laundering to conceal their crimes

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and the money derived from them.

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One common technique is to facilitate the flow of money through a

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legitimate cash-based business, typically owned by affiliates of a

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criminal organization. The supposedly legitimate business brings the

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money into the legal banking system, deposits the money as income,

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which the criminals can then transfer or withdraw.

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There are several ways transfers are disguised to avoid suspicion,

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including

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Transfers to foreign countries

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Depositing cash in smaller increments

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Buying other cash-equivalent instruments

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Another common technique is for launderers to invest the money, using

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dishonest brokers who are willing to ignore the rules in return for

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large commissions.

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Our company is not like that.

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The next slide contains a statement. You will have two seconds to

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think about it, and evaluate if it is true or false.

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Money laundering is the concealment of the origins of illegally

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obtained money.

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The statement was true!

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In this section, we will look into an important process to prevent

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money laundering, customer due diligence.

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Customer due diligence is the process of identifying your clients and

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checking they are who they say they are.

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When you onboard a client, you will need to request certain

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documents, and then you or your staff should review them. You must

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advise your staff of any red flags, for example if the client is

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being evasive.

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Why it CDD important?

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Criminals try to mask their true identity, by providing fraudulent

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documents or using complex ownership structures. The purpose of this

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process is to know a client's identity and understand their business

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activities, so you can properly manage money laundering risks.

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You must understand normal practice in order to detect abnormal

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events and red flags.

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You must perform a risk assessment in the following categories:

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Customer risk: What do they do? Is there business cash intensive?
If

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they sell a product, is it high risk?
If they provide a service, do

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they usually do it remotely, without meeting their clients?
Will they

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receive payments from third parties?
Is the client based in a high-

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risk jurisdiction?

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Once you complete the assessment, our company will categorize the

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client into low, medium or high risk. This risk categorization

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determines which level of due diligence is required to onboard the

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client.

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In the following section, you will need to review some client

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profiles and determine their risk. Would you classify them as high,

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medium or low risk?

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You will have 3 seconds for each scenario.

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Consider this client profile.

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A massage parlour is located in the East Village neighbourhood of New

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York, mostly dealing with cash. They are open during the week days

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from 5PM to 2AM, and do not have any visible internet presence. No

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web site, no social media accounts. While researching the vicinity,

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you discover several news articles about arrests from raids on

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prostitution rings run from ‘massage parlours’, but the client you

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are onboarding was not named in any reports.

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Would you classify them as high, medium or low risk? Why? You have 3

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seconds.

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The correct answer is High Risk.

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This is a cash-intensive business, which automatically requires more

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scrutiny.

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Having no website is odd for a legitimate business today.

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The operating hours are unusual.

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Consider the next profile.

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A small design agency, with a sole director and beneficial owner. The

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business has been trading for five years, with mostly corporate

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clients, and electronic payments. Their profits are in line with

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industry statistics.

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Would you classify them as high, medium or low risk? Why? You have 5

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seconds.

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The correct answer is Medium Risk.

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The business is not cash-intensive, and the structure is simple. The

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company has operated for several years without raising red flags.

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Why not low risk? Refer to ‘Low-risk factors’ within appendix Z of

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the AML guidance.

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