CAMS-Chapters

Chapters Name Content

1. Risks and Methods of - What is Money Laundering?
Money Laundering - Three Stages in the Money Laundering Cycle
and Terrorist Financing • The Economic and Social Consequences of
Money Laundering.
• AML/CFT Compliance Programs and
Individual Accountability.
• Methods of Money Laundering.
• Banks and Other Depository Institutions.
✓ Electronic Transfers of Funds
✓ Remote Deposit Capture
✓ Correspondent Banking
✓ Payable Through Accounts
✓ Concentration Accounts
✓ Private Banking
✓ Use Of Private Invest Companies In
Private Banking
✓ Politically Exposed Persons (Peps
✓ Structuring
✓ Micro structuring
• Credit Unions and Building Societies
• Non-Bank Financial Institutions
✓ Credit Card Industry
✓ Third-Party Payment Processors
✓ Money Services Businesses
✓ Insurance Companies
✓ Securities Broker-Dealers
▪ Variety and Complexity of
Securities
▪ High-risk Securities
▪ Multiple Layers and Third-party
Risk

• Non-Financial Businesses and Professions

✓ Casinos
✓ Dealers in High Value Items (Precious
Metals, Jewelry, Art, Etc.)
✓ Travel Agencies
✓ Vehicle Sellers.
✓ Gatekeepers: Notaries, Accountants,
Auditors, And Lawyers.
✓ Investment and Commodity Advisors.
✓ Trust and Company Service Providers
✓ Real Estate.
• International Trade Activity
✓ Free Trade Zones
 ✓ Trade-Based Money Laundering
Techniques
✓ Black Market Peso Exchange
- Risk Associated with New Payment Products
and Services
• Prepaid Cards, Mobile Payments and Internet-
Based Payment Services.
• Virtual Currency
- Corporate Vehicles Used to Facilitate Illicit
Finance
• Public Companies and Private Limited
Companies
✓ Bearer Shares in Corporate Formation

• Shell and Shelf Companies.

• Trusts.
• Terrorist Financing
✓ Differences and Similarities Between
Terrorist Financing and Money
Laundering
✓ Detecting Terrorist Financing
✓ How Terrorists Raise, Move and Store
Funds
• Use of Hawala and Other Informal Value
Transfer Systems.
• Use of Charities or Non-Profit Organizations
(NPOs)
• Emerging Risks for Terrorist Financing

2. International AML/CFT - Financial Action Task Force (FATF)

Standards • FATF Objectives
• FATF 40 Recommendations
• FATF Members and Observers
• Non-Cooperative Countries
• The Basel Committee on Banking Supervision
• History of the Basel Committee
• European Union Directives on Money
Laundering
✓ FIRST DIRECTIVE
✓ SECOND DIRECTIVE
✓ THIRD DIRECTIVE
✓ FOURTH DIRECTIVE
✓ OTHER RELEVANT LEGAL DOCUMENTS.
• FATF-Style Regional Bodies
✓ FATF-STYLE REGIONAL BODIES AND FATF
ASSOCIATE MEMBERS.
✓ ASIA/PACIFIC GROUP ON MONEY
LAUNDERING (APG).
 ✓ CARIBBEAN FINANCIAL ACTION TASK FORCE
(CFATF).
✓ COMMITTEE OF EXPERTS ON THE
EVALUATION OF ANTI-MONEY LAUNDERING
MEASURES (MONEYVAL)
✓ FINANCIAL ACTION TASK FORCE OF LATIN
AMERICA (GAFILAT).
✓ INTER GOVERNMENTAL ACTION GROUP
AGAINST
✓ MONEY LAUNDERING IN WEST AFRICA
(GIABA).
✓ MIDDLE EAST AND NORTH AFRICA
FINANCIAL ACTION TASK FORCE
(MENAFATF)
✓ EURASIAN GROUP ON COMBATING MONEY
LAUNDERING AND FINANCING OF
TERRORISM (EAG).
✓ EASTERN AND SOUTH AFRICAN ANTI-MONEY
LAUNDERING GROUP (ESAAMLG).
✓ TASK FORCE ON MONEY LANDERING IN
CENTRAL AFRICA (GABAC).
• Organization of American States:
Inter-American Drug Abuse Control
Commission(Comisión Interamericana Para El
Control Del Abuso De Drogas)
• Egmont Group of Financial Intelligence Units.
• The Wolfsberg Group.
• The World Bank and the International Monetary
Fund
• Key US Legislative and Regulatory Initiatives
Applied to Transactions Internationally
• USA PATRIOT Act
• The Reach of the US Criminal Money Laundering
and Civil Forfeiture Laws
• Office of Foreign Assets Control.

3. Anti-Money - Assessing AML/CFT Risk

Laundering/Counter- • Introduction
Terrorist Financing • Maintaining an AML/CFT Risk Model
Compliance Programs • Understanding AML/CFT Risk.
• AML/CFT Risk Scoring
• Assessing the Dynamic Risk of Customers
• AML/CFT Risk Identification
✓ CUSTOMER TYPE.
✓ GEOGRAPHIC LOCATION.
✓ PRODUCTS/SERVICES
- AML/CFT Program
• The Elements of an AML/CFT Program
• A System of Internal Policies, Procedures, and
Controls
✓ AML Policies, Procedures, And Controls
• The Compliance Function
• The Designation and Responsibilities of A
Compliance Officer
✓ COMMUNICATION
✓ DELEGATION OF AML DUTIES
✓ COMPLIANCE OFFICER ACCOUNTABILITY
• AML/CFT Training
✓ COMPONENTS OF AN EFFECTIVE TRAINING
PROGRAM
✓ WHO TO TRAIN
✓ WHAT TO TRAIN ON.
✓ HOW TO TRAIN.
✓ WHEN TO TRAIN.
✓ WHERE TO TRAIN
• Independent Audit.
✓ EVALUATING AN AML/CFT PROGRAM
• Establishing a Culture of Compliance
• Know Your Customer
✓ CUSTOMER DUE DILIGENCE
✓ MAIN ELEMENTS OF A CUSTOMER DUE
DILIGENCE PROGRAM
✓ ENHANCED DUE DILIGENCE
✓ ENHANCED DUE DILIGENCE FOR HIGHER-RISK
CUSTOMERS
✓ ACCOUNT OPENING, CUSTOMER IDENTIFICATION
AND VERIFICATION.
✓ CONSOLIDATED CUSTOMER DUE DILIGENCE
• Economic Sanctions
✓ UNITED NATIONS.
✓ EUROPEAN UNION.
✓ UNITED STATES.
• Sanctions List Screening
• Politically Exposed Persons Screening
• Know Your Employee
• Suspicious or Unusual Transaction Monitoring
and Reporting.
• Automated AML/CFT Solutions
• Money Laundering and Terrorist Financing Red
Flags
✓ UNUSUAL CUSTOMER BEHAVIOR
✓ UNUSUAL CUSTOMER IDENTIFICATION
CIRCUMSTANCES
✓ UNUSUAL CASH TRANSACTIONS
✓ UNUSUAL NON-CASH DEPOSITS
 ✓ UNUSUAL WIRE TRANSFER TRANSACTIONS
✓ UNUSUAL SAFE DEPOSIT BOX ACTIVITY
✓ UNUSUAL ACTIVITY IN CREDIT
✓ TRANSACTIONSUNUSUAL COMMERCIAL
ACCOUNT ACTIVITY.
✓ UNUSUAL TRADE FINANCING TRANSACTIONS
✓ UNUSUAL INVESTMENT ACTIVITY.
✓ OTHER UNUSUAL CUSTOMER ACTIVITY.
✓ UNUSUAL EMPLOYEE ACTIVITY.
✓ UNUSUAL ACTIVITY IN A MONEY REMITTER/
✓ CURRENCY EXCHANGE HOUSE SETTING.
✓ UNUSUAL ACTIVITY FOR VIRTUAL CURRENCY
✓ UNUSUAL ACTIVITY IN AN INSURANCE COMPANY
SETTING
✓ UNUSUAL ACTIVITY IN A BROKER-DEALER
SETTING
✓ UNUSUAL REAL ESTATE ACTIVITY
✓ UNUSUAL ACTIVITY FOR DEALERS OF
✓ PRECIOUS METALS AND HIGH-VALUE ITEMS.
✓ UNUSUAL ACTIVITY INDICATIVE OF TRADE-
BASED MONEY LAUNDERING
✓ UNUSUAL ACTIVITY INDICATIVE OF HUMAN
SMUGGLING.
✓ UNUSUAL ACTIVITY INDICATIVE OF HUMAN
TRAFFICKING.
✓ UNUSUAL ACTIVITY INDICATIVE OF
POTENTIAL TERRORIST FINANCING.

4. CONDUCTING AND - Investigations Initiated by the Financial

RESPONDING TO Institution
INVESTIGATIONS. • Sources of Investigations
✓ REGULATORY RECOMMENDATIONS OR OFFICIAL
FINDINGS.
✓ TRANSACTION MONITORING
✓ REFERRALS FROM CUSTOMER-FACING
EMPLOYEES
✓ INTERNAL HOTLINES
✓ NEGATIVE MEDIA INFORMATION.
✓ RECEIPT OF A GOVERNMENTAL SUBPOENA OR
SEARCH WARRANT
▪ SUBPOENA
▪ SEARCH WARRANT
✓ ORDERS TO RESTRAIN OR FREEZE ACCOUNTS OR
ASSETS
• Conducting the Investigation
✓ UTILIZING THE INTERNET WHEN CONDUCTING
FINANCIAL INVESTIGATIONS

• STR Decision-Making Process

✓ FILING AN STR
✓ QUALITY ASSURANCE
 ✓ STR FILING OVERSIGHT/ESCALATION

• Closing the Account

• Communicating with Law Enforcement on STRs
• Investigations Initiated by Law Enforcement.
• Decision to Prosecute a Financial Institution
for Money Laundering Violations.
• Responding to a Law Enforcement Investigation
Against a Financial Institution
• Monitoring a Law Enforcement Investigation
Against a Financial Institution.
• Cooperating with Law Enforcement During an
Investigation Against a Financial Institution.
• Obtaining Counsel for an Investigation
Against a Financial Institution
✓ RETAINING COUNSEL
✓ ATTORNEY-CLIENT PRIVILEGE APPLIED TO
ENTITIES AND INDIVIDUALS.
✓ DISSEMINATION OF A WRITTEN REPORT BY
COUNSEL
• Notices to Employees as a Result of an
Investigation Against a Financial Institution
• Interviewing Employees as a Result of a Law
Enforcement Investigation Against a Financial
Institution
• Media Relations
- AML/CFT Cooperation between Countries
• FATF Recommendations on Cooperation
between Countries.
• International Money Laundering Information
Network.
• Mutual Legal Assistance Treaties.
• Financial Intelligence Units

5. Glossary of Terms - Glossary of Terms

6. Practice Questions - Practice Questions

7. Guidance Documents and - Other Websites with Helpful AML Material AML
Reference Materials - Related Periodicals