The World Bank Other High Money Laundering Risk Areas Mark Butler Financial Sector Specialist,...
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The World Bank Other High Money Laundering Risk Areas Mark Butler Financial Sector Specialist, Financial Market Integrity, The World Bank April 17, 2006
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Transcript of The World Bank Other High Money Laundering Risk Areas Mark Butler Financial Sector Specialist,...
The World Bank
Other High Money Laundering Risk Areas
Mark ButlerFinancial Sector Specialist,
Financial Market Integrity, The World Bank
April 17, 2006
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Overview- Risk Assessment
- High Risk Customer Policy
- High Risk Customer Types
- High Risk Product Types
- Country Specific Risks
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Risk Assessment
Adopting Risk Based Approach
- Customer Types
- Product Type
- Geographical Factors
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High Risk Customer Policy
Account Opening
- Identify and Verify
- Additional Information
- Senior Management Approval
Account Monitoring
- Type of Monitoring and Frequency
- Renewal of Customer Information
- Renewal of Authority to Maintain Account
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High Risk Customer Types
- Politically Exposed Persons
- Cash Intensive Businesses
- High Risk Business Activities
- Private Banking
- Complex Corporate Structures
- Use of Intermediaries
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High Risk Customer Types
Politically Exposed Persons• Individuals who are or have been entrusted
with prominent public functions in a foreign country, such as Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials
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High Risk Customer Types
Cash Intensive Businesses
- Casinos
- Foreign Exchange
- Remittance Businesses
High Risk Business Activities
- Arms / Chemicals
- Casinos
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High Risk Customer Types
Private Banking
- High Net Worth Individuals
- PEPs
Complex Corporate Structures
Intermediaries
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High Risk Product Types
- Ease of Access to Funds- Passbook / Cheque / ATM / Phone Banking / Internet
Banking
- Ability to Conduct Wire Transfers
- No time restrictions
- Withdrawal charges
- International Access
- Interaction with the Account Holder
- Expected Activity Level within the Account
- Expected Size and Turnover of the Account
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Country Specific Risks
- Low or no AML/CFT regulation
- High Levels of Corruption
- Links to Crime
- Drugs
- Fraud
- Counterfeit Goods
- Illegal Logging
The World Bank
Other High Money Laundering Risk Areas
Mark ButlerFinancial Sector Specialist,
Financial Market Integrity, The World Bank
April 17, 2006
