Within the domain of KYC / AML, “Suspicious Transactions / Red Flags” is one key area that a private banker or wealth manager should be keenly aware of. This course will teach you how to detect and report suspicious transactions. Case studies will be used to deepen the knowledge.
Target Audience
- Private banking heads
- Private banking relationship managers
- Private banking front office customer service officers
- Payment teams
Course Objectives
- Understanding what is a suspicious transaction
- Competent in identifying and raising red flags
- Knowing the obligations and how to detect and report suspicious transaction
Course Outline
Regulatory Developments
- Brief review of anti-money laundering objectives
- Front office as first line of defence
- Obligation to detect and report suspicious transactions
How to Identify Suspicious Transactions
- Diligence and reasonable grounds
- No value threshold
- Mosaic theory
Red Flags
- Long list of possible indicators pointing to suspicious transaction such as:
- Pressure to open account or transact quickly
- Customer is too friendly or too secretive
- Opening a few accounts or having many related accounts
- List of known and suspected terrorists
- FATF high-risk and non-cooperative jurisdictions
Continual Monitoring
- Monitor and review account and transactions to raise red flags
- Identify suspicious activity
- Reporting of suspicious transactions
Reporting Process
- Escalating to compliance
- Keep proper record of basis for suspicion and action taken, if any
- Escalating to senior management
- Filing a suspicious transaction report to authorities
- Promptness
- Principle of confidentiality
Follow Up Action
- Course of action to mitigate risk
- Pinpoint new account “owner” and liaison with authorities
- Movement (freezing) of funds
- Review of related and associated accounts
- Review of guidelines
- Training
Conclusion
- Risk of non-compliance
- Enterprise/Corporate
- Personal