United Bank of Development (UDB) Manual: Preventing Money Laundering and Terrorism Financing

Deliberate Obfuscation and Deception

In an effort to avoid detection by financial institutions like the United Bank of Development (UDB), individuals or groups may attempt to structure transactions in a way that obscures their true nature. This can involve:

• Omitting information from documentation
• Deliberately disguising or falsifying information
• Structuring transactions to avoid detection by third parties

Phantom Shipping and Falsified Documentation

In some cases, no goods may be shipped at all, and all documentation related to the transaction is completely fabricated. This is a red flag for potential money laundering or terrorism financing activities.

UDB’s Controls and Procedures

To prevent and detect money laundering and terrorism financing, UDB has implemented various controls and procedures:

• Trade Transaction Review: The bank reviews each trade transaction individually for signs of fraud, sanctions, and suspicious activity.
• Automated and Manual Screening: UDB uses a combination of automated (WORLD CHECK) and manual controls to screen parties involved in transactions against potential matches in the WORLD CHECK database. If a match is found, suspicious transactions rules apply.

Suspicious Transaction Reporting

Transactions that appear unusual or lack financial or business purpose may be considered suspicious and require further investigation:

• Filing Reports: The Money Laundering Reporting Officer will file a report with the Financial Intelligence Authority if they deem a transaction to be part of an activity related to money laundering, terrorism financing, or fraud.

Record Keeping and Compliance

To ensure compliance with regulations and maintain transparency:

• Documentation Retention: UDB must keep documentation obtained during Know Your Customer (KYC) and due diligence procedures for at least 10 years.
• Transaction Records: The bank must also retain original documentation or certified copies of transactions carried out through the UDB platform for at least 10 years.
• Suspicious Transaction Reports: UDB must maintain records of reports issued by the bank.

Staff Training and Education

Creating a culture of compliance among staff is essential in combating money laundering and terrorism financing:

• Mandatory Knowledge and Compliance: The bank will make this manual and related regulations part of its internal procedures, and knowledge and compliance will be mandatory for all staff.
• Internal Procedures: UDB believes that creating a culture of control and compliance among staff is crucial in preventing and detecting financial crimes.