The process where gambling winnings is invested into financial markets.
The process where money exchange programs are setup.
The process where illegal gains are to 'cleaned' in order to hide the orgin of the cash.
The monthly pay process at Amwal.
Integration, Leaving & Depositing
Depositing, Integration & Exchange
Placement, Harrassment & Substitution
Placement, Layering & Integration
'Sound Transaction Record' and inform Sateesh in IT.
'Secret Terms Record' and inform MLRO who investigates and informs QCB.
'Strange Transaction Record' & inform the MLRO who investigates and reports to the FIU.
All the above.
Crimes Financial Testing
Combating the Financing of Terrorism
At an early stage after about the 2nd/3rd meeting?
Near the latter stages prior to signing a contract?
When you have time?
After signing a contract?
To identify, verify and assess.
To identify, have lunch with and take their money.
To identify, verify and record.
To run WorldCheck and Google checks.
The direct client we are dealing with.
The direct client plus immediate major shareholders.
The ultimate major Beneficial Owner(s).
When it becomes too boring or tedious.
'Risky but Exciting Approach'
'Risk Based Approach'
'Legal, Compliant and Financial Approach'
The rules of Law 29 of the State of Qatar 2005
Customer Facing Staff
Google/Internet/News searches. To verify source of funds. Regular reviews. Assessment and checks on the PEPs immediate family and known colleagues/friends/companies. MLRO sign off and risk rating.
Wikipedia checks and World checks. MLRO sign off.
Spy on the PEP and bug his home. MLRO sign off.
Checking bank statements and asking for police reports. MLRO sign off and risk rating.
Unrealistic wealth compared to profile.
Trades with no/little benefits and losses without concern.
Large/rapid movement of funds.
All the above.
Can give financial advise as already a client?
Can offer to 'opt up' the client if they qualify? Otherwise can have a 'factual' conversation without financial advise.
Cannot speak to them at all and politely ask them to leave.
Offer them tea and have a nice catch up.
If they work for a financial institution and have enough skills and experience.
If they have over $1m in liquid assets.
If they have over $1m in liquid assets and the firm is satisfied that they have sufficient knowledge and understanding to invest.
All the above.
A & C only.
Cash intensive business eg money transfer, casinos etc.
Customers with complex structures that make identifying ownership difficult.
A PEPs stockbroker.
A customer whose ownership structure is through 'bearer shares'.
Other regulated financial institutions.
Government and Public Authorities.
Its more flexible, as risks vary across juridictions, customers, products and delivery channels.
Its more effective - Firms can assess and mitigate risks at a more personal level.
Its more proportionate - more common sense than a 'tick the box' approach.
It is a fool proof system.
Board of Directors
Senior Management & Staff
All of the Above
That all staff need driving licenses.
That all staff must have nice CVs.
That the firm monitors the ongoing training and competency of staff.
The firm monitors the diets of all staff.
Be a listed Company.
Be a retail Client
A Retail Client who has $1m in net assets and sufficient knowledge to transact.
Must be a really nice, smiley person. Who we all like!