§ Overview of AML and CTF Legislation
(including latest HKMA revised AML Guideline, Supplement and Interpretative
Notes; FSTB consultation on proposed AML legislation)
§ Establishing an AML monitoring system
§ KYC – client identification
techniques
o
Face
to face interviews (by RM) – what to say and how to ask?
o
Application
forms / account opening forms – what should be in there?
o
Beneficial
Owner’s account: how to trace ultimate beneficial owners? How “deep”
should you go given that money launderers usually use tax haven jurisdictions
and trusts
o
Document
collection – what to collect for the following categories:
§
Individuals
§
Corporates – privately owned v.
public listed companies; factors to consider: place of incorporation and
purpose of company
§ Trusts – how far should you go? Beneficiaries?
Registered Trustee v. Private trustee
§ Limited Partnerships
§ Financial Intermediary / Institutions
§ Fund – differences between corporate,
trusts & LPs – can you go and get info on end investors – e.g. what would
be the % threshold – anyone single 1 investor over 10%?
§
Politically
Exposed Persons (PEP) – who are considered to be PEP? What type of enhanced due
diligence?
o
Independent
due diligence: various databases / checklists – how reliable are they?
§ Transaction monitoring – how to
effectively monitor suspicious transactions
o
Typical
red flags for money laundering and terrorist financing – what are they?
o
Suspicious
transaction reporting – how to do that? Does it affect client
relationship? Confidentiality issues and other concerns
§ How to ensure that AML / CTF programme has been complied with
o
Staff
training / education
o
Internal
controls
§ Case Studies – ML cases relating to
Financial Institutions
