Anti-Money Laundering. Anti Money Laundering is a set of procedures, laws or regulations designed to stop the practice of generating income through illegal actions. Oracle Financial Services Anti Money Laundering Gain a Holistic View of All Transactions and Activities. Provides an enterprise platform enabling efficient detection. METAVANTE WHITE PAPE R Customer Risk Assessment Christopher Price Metavante Compliance Consultant. The Certified Anti-Money Laundering Specialist (CAMS) certification is the gold standard in AML examinations.

Anti- Money Laundering - CFTCThe Patriot Act, which amends the Bank Secrecy Act (BSA), was adopted in response to the September 1. The Patriot Act is intended to strengthen U. S. These efforts include anti- money laundering (AML) tools that impact the banking, financial, and investment communities. As a result of the Patriot Act, persons who are or are required to be registered as futures commission merchants (FCMs), introducing brokers (IBs), commodity pool operators (CPOs), and commodity trading advisors (CTAs) are or may become subject to requirements for establishing AML programs, reporting suspicious activity, verifying the identity of customers, and applying enhanced due diligence to certain types of accounts involving foreign persons.

Establishing AML Programs. Reporting Suspicious Activity. Verifying the Identity of Customers. Due Diligence Measures for Certain Accounts Involving Foreign Persons. Special Measures.

Actimize, Inc., a wholly owned subsidiary of NICE Systems, provides financial crime prevention, compliance and risk management products and services to the financial.

Transactions in Excess of $1. Currency. Foreign Bank and Financial Accounts. International Transportation of Currency or Monetary Instruments. Information Sharing among Financial Institutions and Law Enforcement. Additional Resources. By order dated September 2. Secretary of the Treasury (Treasury) delegated its authority to administer the BSA to the Financial Crimes Enforcement Network (Fin.

CEN). Establishing AML Programs. The Patriot Act amended the BSA to require that financial institutions establish AML Programs. FCMs, CPOs, and CTAs are specifically included in the definition of financial institution in the BSA. IBs are considered to be .

An AML Program must be in writing and must include: the development of internal policies, procedures, and controls; the designation of a compliance officer; an ongoing employee training program; and an independent audit function to test programs. Treasury has adopted interim final rules regarding AML Programs for financial institutions (as subsequently amended in 2. These rules exempt CPOs and CTAs from the AML Program requirement pending the issuance of final rules. Treasury had proposed rules that would have required unregistered investment companies (UICs), including commodity pools, and commodity trading advisors to establish and implement written anti- money laundering programs, but Treasury withdrew the UIC and CTA proposals.

The National Futures Association has adopted Rule 2- 9(c) and an accompanying Interpretive Notice regarding AML Programs for its FCM and IB members. Other AML Program rule notices for specified financial institutions include: On March 5, 2. Fin. CEN, the Securities and Exchange Commission, and the Banking agencies (the Federal Reserve, Comptroller of the Currency, Federal Deposit Insurance Corporation, Office of Thrift Supervision, National Credit Union Administration) in consultation with the CFTC, issued guidance addressed to the core requirement to develop and implement internal controls, policies and procedures as part of a firm's anti- money laundering program. Reporting Suspicious Activity. The Patriot Act authorizes Treasury to issue rules requiring FCMs, CPOs, and CTAs to file Suspicious Activity Reports (SARs).

Treasury has issued a final rule requiring FCMs and IBs to file SARs. Treasury has not yet proposed a rule requiring CPOs and CTAs to file SARs. Treasury also has issued a Form 1. Suspicious Activity Report by the Securities and Futures Industries (SAR- SF) (with instructions), which FCMs and IBs must use to report suspicious transactions, and which CPOs and CTAs may use to report voluntarily. Treasury has also posted guidance on common errors found in filed SARs. Comunicado Presentacion Del Libro De Compras Y Ventas Iva Software there.

Verifying the Identity of Customers. The Patriot Act requires Treasury to issue rules setting forth minimum standards for financial institutions to identify and verify the identity of customers. Treasury and the CFTC have jointly issued final rules (with a subsequent correction) that require FCMs and IBs to have customer identification programs (CIPs) for identifying and verifying the identity of customers.

An FCM's or IB's procedures must enable it to form a reasonable belief that it knows the true identity of each customer. Pursuant to a staff no- action letter issued on March 1.

FCMs and IBs may rely upon certain CTAs to perform procedures of the FCM's or IB's CIP even though such CTAs are not yet subject to an AML program rule. Final rules regarding customer identification programs have also been issued for banks, savings associations, credit unions, and certain non- federally regulated banks; broker- dealers, and mutual funds. The rules are substantively identical for all affected sectors of the financial services industry. These rules require that financial institutions have procedures for checking customer's names against lists of known or suspected terrorists or terrorist organizations that are prepared by any federal agency and made available to the institution.

Although no lists have yet been designated, financial institutions are separately required to comply with the rules of the Office of Foreign Assets and Control (OFAC) and must consult OFAC's lists of sanctioned countries and specially designated nationals and blocked persons. Sources for complying with OFAC rules: The staff of the CFTC and Treasury also has jointly issued guidance, in question- and- answer format, regarding the application of the CIP rule for FCMs and IBs.

This guidance covers a number of topics that were not explicitly addressed by the CIP rules. One important area of staff guidance addresses the situation where an omnibus account or sub- account or relationship is established by or on behalf of a financial intermediary for the purposes of executing transactions that clear or settle at another financial institution. The staff of Treasury and the CFTC has issued guidance that clarifies that if the financial intermediary is the account holder, the intermediary can be treated as the customer for the purposes of the CIP rule. Another important area of staff guidance addresses the CIP requirements applicable to FCMs engaged in give- up transactions. A final rule (as amended in 2. Treasury requires covered financial institutions, including FCMs and IBs, to establish due diligence programs that include appropriate, specific, risk- based, and where necessary, enhanced policies, procedures and controls that are reasonably designed to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered, or managed by such covered financial institution in the United States for a foreign financial institution.

The same rule also requires covered financial institutions, including FCMs and IBs, to maintain due diligence programs that are reasonably designed to detect and report known or suspected money laundering or suspicious activity conducted through or involving any private banking account that is established, maintained, administered, or managed in the United States by such financial institution for a non- U. S. The due diligence program must ensure, at a minimum, that the financial institution takes reasonable steps to ascertain the identity of the nominal and beneficial owners of the private account, whether any such person is a senior foreign political figure, the sources of funds deposited into the private banking account and the purpose and expected use of the account. The program also must ensure that the financial institution reviews the activity in the private banking account to ensure it is consistent with the information obtained about the client and reports known or suspected money laundering or suspicious activity conducted to, from or through the private banking account.