One of the main Anti-Money Laundering (AML) requirements as set out in AML/CFT State Ordinance is the reporting of unusual transactions to the Financial Intelligence Unit (FIU -formerly known as Meldpunt Ongebruikelijke Transactie, MOT).
The unusualness may arise from the characteristics, size, or nature of the transaction or from any other circumstances that come to the reporting institution’s attention by reason of its functions, and taking account of the economic capacity or business activity of the persons carrying out the transaction. The unusualness must be grounded in a comprehensive assessment of all elements – objective and subjective – of the transactions that are known to the reporting institution, acquired in the course of the customer’s business relationship.
All service providers are required to report a carried out or intended unusual transaction without delay after the unusual nature of the transaction has become known to it to the FIU/MOT.
- Legal requirements
- Criminalization of Money Laundering & the Financing of Terrorism
- The process of Money Laundering
- What is meant with “unusual”?
- Carried out (completed) or intended transactions
- How to identify an Unusual Transaction?
- When is a transaction unusual?
- What are intended transactions?
- When and how to monitor transactions?
- Triggers – monitoring – alerts – adverse media etc.
- Assessing negative media information
- Conducting a investigation – internet search – open sources
- How to conduct an investigation prior to reporting an unusual transaction?
- Reporting procedures – Internal & External– When to report?
- Indicators of Unusual Transactions: objective and subjective indicators
- The reporting obligation on the subjective indicators: When does a transaction give cause to assume that this may be related to money laundering and/or terrorist financing?
- The quality of Unusual Transaction Reports
- The importance of the civil and criminal indemnification (vrijwaring)
- Which steps must be taken after an unusual transaction report has been submitted by the FIU to the relevant law enforcement agency?
- Exiting clients – closing the account – rejecting new clients
- The risk and consequences of Tipping Off – Confidentiality
- Request for further information by FIU
- Dealing with subpoenas and or search warrant – responding to a Law Enforcement Investigation
- Orders to restrain or freeze accounts or assets
- What happens if you fail to comply with your obligation to report?
- Penalties for non-compliance – Who can be held responsible?
- Money Laundering Compliance Officers
- Money Laundering Reporting Officers
- Other Compliance staff
- Personnel involved with transaction monitoring
This training will guide you through the process of reporting unusual transactions; from triggers and suspected suspicious/unusual transactions to the evaluation thereof and ultimately to completed comprehensive reports to the FIU. This course will be highly interactive, hands-on, and real-world approach. This training is highly interactive with discussions and case studies.
There are no requirements for participation.
Duration of the training
The duration of the training is 4 hours.
AWG 445,- pp. (incl. taxes)
Costs includes: Training sheets and Certificate of participation
Date: September 8, 2021.
Time: 8:30 – 12:30
Location: This training will be held at the training center of Compliance Services Caribbean located at Caya Taratata 3-A, Unit 16 (Opposite RBC Bank Italiëstraat).