New European AML

Challenges and Strategies

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Moderator

Kieran Beer, CAMSEditor-in-Chief

ACAMS moneylaundering.com

Speakers

Jennifer Hanley-Giersch, CAMS, CFCSManaging PartnerBerlin Risk Limited

Zia UllahPartner

Eversheds Financial Services

AGENDA• ACAMS Europe Update

Angela Salter, Head of Europe, Association of Certified Anti-Money Laundering Specialists

• The Fourth Anti-Money Laundering Directive:

Jennifer Hanley-Giersch, CAMS, CFCS, Managing Partner, Berlin Risk Limited

• Sanctions & Lessons from Enforcement Actions:

Zia Ullah, Partner, Eversheds Financial Services

ACAMS Europe Training Update

European Seminars

• December 2015 Warsaw, London

• February 2016 Amsterdam, Paris, Stockholm

• March 2016 Frankfurt

European Webinars

• Quarterly 2015

• Bi-monthly 2016

ACAMS Europe Chapter Update

Country/Region Status Live / target launch date

Bulgaria Some local interest

Cyprus Much interest. Looking for Board Members Q4

France

Meets every 3/4 months. Seeking additional board

members Live

Germany Board in place Q3/4

Ireland Much interest. Looking for Board Members Q4

Latvia - Baltics Some local interest

Luxembourg Format changing Live

NL Meets every 3 months Live

Nordics Much interest. Looking for Board Members Q4

Poland Researching local interest

Serbia / W. Balkans Much interest. Researching.

Spain Much interest. Looking for new Board Members

UK Meets every 3 months Live

4th EU AML Directive

• Background and some key facts

• Enhanced Risk-based approach

• Beneficial ownership

• Politically Exposed Persons

• Risk Assessment and Challenges to CDD

• Sanctions

Some key facts

• The fourth AML directive came into force on 25 June 2015

• Implementation should be completed by 26 June 2017

• Enhanced risk-based approach

• Politically Exposed Persons expanded

• Beneficial ownership

• Sanctions

Enhanced Risk-based approach

PEPS expanded

• Politically exposed person’ means a natural person who is or who has been entrusted with prominent public functions and their family members and persons known to be close associates’.

• The politically exposed person status should be applied for a period of 12 months after they leave office.

• Middle- ranking or more junior officials are not included in this definition.

PEPS expanded contd.

• Appropriate risk management systems, including risk-based procedures, to determine PEP status. • obtain senior management

• adequate measures to establish the source of wealth and source of funds

• conduct enhanced, on-going monitoring

Beneficial ownership

• Member States must ensure that all entities including foundations and trusts hold adequate, accurate and current information on beneficial ownership.

• Member States should ensure that beneficial ownership information is stored in a central register.

Beneficial ownership contd.

• Definition: ‘beneficial owner’ means any natural person(s) who ultimately owns or controls the customer and/or the natural person(s) on whose behalf a transaction or activity is being conducted.

• Identifying the beneficial owner and taking reasonable measures to verify that person’s identity.

• Taking reasonable measures to understand the ownership and control structure of the customer.

Risk Assessment & CDD

• Identify situations where risk of money laundering or terrorist financing is high and undertake EDD.

• In particular in relation to PEPS and in dealing with countries where corruption is widespread.

• Risk variables to define extent of CDD:• Purpose of an account or relationship

• Level of assets to be deposited / Size of transaction

• Regularity of duration of the business relationship

Risk Assessment & CDD contd.

• Filter out potentially lower or higher risk customers according to risk factors: • Customer risk factors

• Product, service, transaction or delivery channel risk factors

• Geographical risk factors

Sanctions

P5 + 1 and Iran JCPOA

(Joint Comprehensive Plan of Action)

• What is the timeline?

• What is the practical impact?

• Convergence or Divergence?

• Horizon Scanning: Where will we be in 5 years?

Lessons from Recent Enforcement Actions

•Bank of Beirut

• The rise of personal liability

• The senior manager’s regime

CAMS-FCI and CAMS-Audit are moving to New York City.

Upcoming Program: October 19-21, 2015

REGISTRATION IS NOW OPEN!

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