SGI AML TRAINING27.07.15

Tennille Ramlal

Table of Contents• Training Objectives

– AML Objectives– What is Money Laundering ?– Who are Responsible ?– Know Your Customer Procedures– – Revisiting Current Process– Introduction of checklist for Brokers with Binding Authority– Repercussions for Non Adherence

AML Objectives

• To prevent, detect and report suspected acts of Money Laundering & Terrorist Financing.

What is Money Laundering ?

• The process by which the direct or indirect benefit of crime is channeled through financial institutions to conceal the true origin and ownership of the proceeds of criminal activities. If undertaken successfully, the money can lose its criminal identity.

Who are Responsible • Everyone

– Underwriters (I, II, III)– Cashiers– Agents– Agencies– Brokers with Binding Authority– Brokers without Binding Authority– Supervisors, Management, VP’s, CEO

Know Your Customer Procedures

• Individuals– Proof of Identification - 2 Forms ID (National ID, Driver’s License,

Passport)– Proof of Address (Utility Bill, Bank Statements, Credit Card Statements)– KYC Form (Completed in its entirety)– Declaration of Source of Funds Forms - $60TT or equivalent & over– Determine whether client is a PEP, if yes submit to CO for Enhanced

Due Diligence and Approval– Perform a Bridger search on the client’s name to ensure that the client

is not on the terrorists or watch list ( refer to CO or BUCO)

Know Your Customer Procedures• Companies

– Corporate KYC Form– Registration Documents ( Certificate of Incorporation etc)– 2 Forms of ID’s & Proof of Address for the following :-

• Directors • Substantial Shareholders (10% & above)• Authorized Signatories & Senior Officers

– Last 3 years Audited Financials or Management Accounts– Appropriate License (Where required)– Declaration of Source of Funds Forms – TTD $60K or equivalent & over– Determine whether any director, Substantial Shareholder or Senior Officer

is a PEP, if yes submit to CO for Enhanced Due Diligence and Approval– Perform a Bridger search on the Company and its directors etc to ensure

that they are not on the terrorists or watch list ( refer to CO or BUCO)

SOFD Example - Individual

SOFD Example – Broker/Company

• Due Diligence & Record Keeping Procedures Requirements

Revisiting the Current Process• Who can tell us the procedures ?

Introduction to Checklist for Brokers with Binding Authority

Repercussions of Non Adherence• The Person(s) fined and jailed

– Compliance Officer– Senior Management– Staff Members involved in the transaction

• Company fined hefty penalties

• Loss of reputation both company & individual

• Closure of company

• Loss of jobs to individuals involved

We thank you for your attendance !

Questions ?