Financial Crime World

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Prevention of Money Laundering and Terrorist Financing

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General Provisions

The Financial Services Unit (FSU) is responsible for enforcing anti-money laundering and terrorist financing laws. To ensure compliance, the FSU must perform inspections to verify that entities and professionals are maintaining a written system of internal controls to detect and prevent money laundering and terrorist financing.

Training of FSU Staff

  • The FSU must train its staff on conducting on-site and off-site inspections of entities and professionals.
  • The training should enable inspecting staff to assess the quality of internal procedures, risk management policies, and compliance functions.
  • The training should also cover:
    • Participation of senior management
    • Employee understanding of anti-money laundering laws
    • Level of awareness among front-desk staff

Establishing Internal Control Systems

Entities and professionals must establish a written system of internal controls to detect and prevent money laundering and terrorist financing. This system should be framed in a way that enables the entity or professional to assess risks and be appropriate to its circumstances.

A written system of internal controls should include:

  • Increased focus on vulnerable operations
  • Regular reviews of risk assessment and management policies
  • Designation of an individual responsible for managing anti-money laundering compliance
  • Provision for an anti-money laundering compliance function and review programme
  • Risk-based customer due diligence policies
  • Additional controls for higher-risk customers, transactions, and products

Record Keeping and Reporting

Entities and professionals must maintain records of their anti-money laundering activities. They must also report suspicious transactions to the FIU in a timely manner.

Disciplinary Measures

Employees who fail to make or timely reports of internal suspicious activity or transactions may face disciplinary measures.

These sections highlight the importance of maintaining a robust system of internal controls, conducting regular inspections, and ensuring that employees are aware of anti-money laundering laws.