Learning Objectives:
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Understand the AML/CFT framework and its key components.
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Apply Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements.
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Identify and report suspicious activity.
4.1 The AML/CFT Framework
The EM Normandie module covers “Anti- Money Laundering (AML) and Financial Crime Prevention” and “AML laws and compliance frameworks” . The University of Edinburgh module covers “financial crimes part 1 – money laundering and terrorist financing” .
Key components:
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Risk-Based Approach: Enterprise-wide risk assessments.
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Customer Due Diligence (CDD): Identifying and verifying customer identity.
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Enhanced Due Diligence (EDD): For high-risk clients.
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Transaction Monitoring: Monitoring transactions for suspicious patterns.
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Suspicious Activity Reporting (SAR/STR): Filing reports with Financial Intelligence Units.
4.2 Know Your Customer (KYC) and Customer Due Diligence
The EM Normandie module covers “Know Your Customer (KYC) and Customer Due Diligence (CDD) requirements” . Key elements include:
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Customer Identification Program (CIP): Collecting and verifying basic identifying information.
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Beneficial Ownership Identification: Identifying the individuals who ultimately own or control legal entities.
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Risk Profiling: Categorising customers as low, medium, or high risk.
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Ongoing Monitoring: Continuously reviewing transactions and updating customer information.
4.3 Sanctions and Counter-Terrorist Financing
The EM Normandie module covers “sanctions compliance and counter- terrorist financing (CTF)” . The University of Edinburgh module covers “terrorist financing” as a core topic . Banks must screen customers and transactions against sanctions lists and report any matches to the relevant authorities.