Financial Crime World

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Unique Transaction Number and Financial Compliance Guidelines

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In the world of finance, a unique transaction number refers to a combination of letters, numbers or symbols determined by payment service providers in accordance with the protocols of the payment and settlement system or messaging system used for wire transfers.

VASP: Virtual Asset Service Providers

Virtual Asset Service Providers (VASPs) are entities that provide services related to virtual assets such as cryptocurrencies. They must comply with anti-money laundering (AML), combating the financing of terrorism (CFT) and proliferation financing (CPF) regulations.

Part IA: AML/CFT/CPF Internal Programmes and Obligations of the Board of Directors

The Board of Directors of a financial institution is responsible for ensuring that the institution has internal programmes and policies in place to prevent money laundering, terrorism financing and proliferation financing. The Board must also ensure that employees are trained and aware of their responsibilities under AML/CFT/CPF regulations.

General Principles and Policies to Combat Money Laundering, Terrorism Financing and Proliferation Financing

Financial institutions must take necessary steps to prevent money laundering, terrorism financing and proliferation financing. This includes:

  • Ensuring compliance with laws and regulations
  • Cooperating with law enforcement agencies
  • Establishing internal controls
  • Implementing a risk-based approach
  • Conducting customer due diligence

TFS-PF: Targeted Financial Sanctions on Proliferation Financing

The United Nations Security Council (UNSC) has imposed targeted financial sanctions on countries and specifically identified individuals and entities to prevent the proliferation of weapons of mass destruction. Financial institutions must implement these sanctions without delay.

Part IB: Obligations of the Board of Directors, Senior Management and Employees

The Board of Directors, senior management and employees of a financial institution have specific obligations under AML/CFT/CPF regulations. These include:

  • Ensuring compliance with laws and regulations
  • Implementing internal controls
  • Conducting ongoing training programmes

Risk-Based Approach to Combat Money Laundering, Terrorism Financing and Proliferation Financing

Financial institutions must implement a risk-based approach to identify, assess, monitor, manage and mitigate money laundering, terrorism financing and proliferation financing risks. This includes:

  • Ensuring that policies and procedures are commensurate with the nature, scale and complexity of activities

Customer Due Diligence: A Key Compliance Requirement

Financial institutions must have an effective procedure to identify customers and obtain satisfactory evidence to verify their identity. This is a key compliance requirement under AML/CFT/CPF regulations.

FIED: Financial Intelligence and Enforcement Division

The Financial Intelligence and Enforcement Division (FIED) is responsible for receiving and investigating reports of suspicious transactions from financial institutions. Financial institutions must report any suspected money laundering, terrorism financing or proliferation financing transactions to the FIED without delay.

Part IC: Reporting of Suspected Transactions and Obligations under the AMLA

Financial institutions are required to report any suspected money laundering, terrorism financing or proliferation financing transactions to the FIED. The institution must also ensure that employees are aware of their obligations under the Anti-Money Laundering Act (AMLA) and these guidelines.

Part ID: Ongoing Training and Awareness Programmes

Financial institutions must conduct ongoing training programmes for the Board of Directors, senior management and employees to keep them abreast of matters under the AMAL and these guidelines. This includes:

  • Ensuring that all employees understand their roles and responsibilities in preventing money laundering, terrorism financing and proliferation financing.

Part II: Guidelines for Financial Institutions

The following guidelines are intended to provide financial institutions with a comprehensive framework for complying with AML/CFT/CPF regulations. The guidelines cover various aspects including risk assessment, customer due diligence, reporting of suspicious transactions and ongoing training programmes.