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Course details

Dates are currently being finalised. Get in touch to find out more
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Anti-Financial Crime Compliance & Risk Management

Learn the essentials of Financial Crime compliance and their importance for all risk departments
  • This three day training programme has been developed for professionals working in the financial services industry globally and covers:
    • What is Anti-Financial Crime (AFC) compliance?
    • The programme will review financial crimes including bribery and corruption, cybercrime, fraud, market abuse, money laundering, sanctions, terrorist financing, and weapons proliferation
    • Review of the international AFC compliance regime for financial services firms
    • Responsibilities of regulators, firms, senior management and staff
    • Should firms be doing more to combat financial crime?
    • What is your firm’s AFC strategy?
    • What are the financial crime risks in achieving your firm’s commercial ambitions?
    • Role and responsibilities of the AFC Compliance Function
    • Being an AFC Compliance Officer/Money Laundering Reporting Officer (MLRO)
    • Working with senior management, business lines, control functions, and regulators
    • Risk identification, measurement, assessment and management
    • Are you complying?
    • Maintaining policies and procedures, systems and controls: best practices
    • The importance of keeping good records
    • Customer due diligence – do you really know your client?
    • Suspicion reporting – what should you report? – when should you be suspicious?
    • Are human beings your weakest link? Delivering effective training and awareness
    • Challenges of investigations, enforcement and litigation
    • Programme will include many casestudies reviewing lessons to be learnt from enforcement actions, and many typologies.


    Learning Objectives


    • Provide advanced training on AFC compliance requirements
    • Increase awareness and understanding of risk-based AFC compliance best practices
    • Provide practical tools for AFC compliance.

    Who Should Attend?


    This course has been designed for financial services professionals including:
    • Anti-Financial Crime
    • Compliance
    • Legal
    • Governance
    • Risk managers
    • Internal and external audit
    • Law enforcement and regulators
    • Professional advisers

  • Day 1

    09.30 – What is AFC Compliance?


    Bernie Madoff Casestudy: lessons to be learnt for financial institutions
    • Why is it important for financial institutions to combat financial crime?
    • Should firms be doing more?
    • Internal and external threats: bribery and corruption, cybercrime, fraud, market abuse, money laundering, sanctions, terrorist financing, and weapons proliferation
    • What does achieving effective compliance look like?
    • Can you ever be sure your firm is and will remain compliant?
    • Who is primarily responsible for the firm’s compliance?
    • The role and responsibilities of senior management and AFC Compliance
    • Compliance’s independence from the business lines
    • Revenue generation: does good compliance mean good business?
    • The Three Lines of Defence: the role and responsibilities of Compliance
    • Risk assessment, advice, guidance, education, monitoring, testing and reporting
    • Maintaining policies and procedures, systems and controls
    • Working with Financial Intelligence Units and law enforcement
    • Protecting your firm’s reputation in an age of financial turbulence
    • Is compliance an integral part of your firm’s business activities?
    • Does your firm have a compliance culture?
    • Are we winning the war against financial crime?

    10.30 Bribery and Corruption Essentials

    11.00 – Morning Coffee

    11.30 – AFC Compliance: The International Regime
    • Financial institutions – in the front line of the war on financial crime
    • Assessing risks and applying a risk-based approach
    • United Nations – Conventions and Resolutions
    • Basle Committee – Core Principles Effective Banking Supervision
    • Basle – abuse of financial services, supervisory powers, responsibilities and functions
    • Focus upon robust corporate governance
    • Your firm’s strategy, organisational structure, control environment and compensation
    • Managing risk – does your firm have a comprehensive risk management process?
    • Basle Committee – Compliance and the Compliance Function in Banks
    • Responsibilities of the Board and senior management for compliance
    • Compliance should be independent and work with the business
    • Compliance function responsibilities: do you have sufficient resources?
    • The Financial Action Task Force (FATF), recommendations and current initiatives
    • International Standards on Combating Money Laundering and the Financing of Terrorism
    • Egmont Group of Financial Intelligence Units
    • National AFC regimes: civil, criminal and regulatory liabilities
    • Transnational business: the challenges for national regulators and law enforcement.

    12.30 – Cybercrime Essentials
    13.00 – Lunch
    14.00 – Responsibilities of Regulators, Firms, Senior Management and Staff
    • The nature of regulation beyond the financial crisis
    • Authorisation, ongoing supervision and enforcement
    • Firm to take reasonable care to organise and control its affairs responsibly and effectively with adequate risk management systems
    • How robust is your firm’s control environment?
    • The responsibilities of the Board and senior management
    • What is your firm’s strategy and risk appetite?
    • Corporate structure, resourcing, internal organisation, reporting lines and job descriptions
    • Who is responsible for what? Individual responsibilities and accountability
    • AFC Compliance policies and procedures
    • Do you have appropriate systems and controls to combat financial crime?
    • “The Tone from the Top” – maintaining a compliance culture.

    Systems and Controls Casestudy: review of the lessons to be learnt from a regulatory enforcement action about a Senior Manager’s “reasonable steps” responsibilities
    15.00 – Money Laundering Essentials
    15.30 – Afternoon Tea
    16.00 – Being an AFC Compliance Officer/MLRO: Your Role and Responsibilities
    • What are the attributes of an effective AFC Compliance Officer and MLRO?
    • Qualifications, experience and personal qualities
    • Recognising the challenges and personal demands of your role
    • Working with management, business lines, control functions, regulators, law enforcement
    • Understanding your firm’s businesses and their strategies
    • To whom are you accountable? Stature, authority and independence
    • Technical compliance expertise and the exercise of judgement
    • Reporting obligations: to whom and what to report?
    • Cross-border compliance: achieving consistency across all the business lines everywhere
    • Overseeing the operation of a risk based approach and the implementation of policies and procedures, systems and controls
    • Managing a compliance function and its staff
    • Internal and external communications
    • Achieving compliance in the age of the auditor
    • How good are you at dealing with trouble?

    Casestudy: review of regulatory enforcement actions against Compliance Officers
    17.00 – Close


    Day 2


    09.30 – Risk Identification, Measurement and Assessment
    • Basle Principles – does your firm have a comprehensive risk management process?
    • FATF Recommendations – assessing risks and applying a risk-based approach
    • Is the risk-based approach working or is it a new form of tick box compliance?
    • What is your firm’s business strategy and risk appetite?
    • What are the compliance risks in achieving your firm’s commercial ambitions?
    • Reputational risk: should we really be doing this business?
    • Conducting an effective and auditable risk assessment
    • Are your risk assessment and management processes tailored to the needs of your firm?
    • Assessing risk in a changing environment: new products and business models
    • What are the regulatory rules and expectations?
    • What are your “Key Risk Indicators”?
    • Working with and briefing Senior Management on the results of your risk assessment
    • How effective are your risk management processes?
    • Does the firm have a robust risk management culture?
    • How can you best mitigate your risks?
    • Producing a risk-based compliance programme.

    10.30 – Terrorist Financing Essentials
    11.00 Morning Coffee
    11.30 – Are You Complying?
    • Are your risk mitigators clearly linked to the findings of your risk assessment?
    • Does the firm maintain a properly controlled operating environment?
    • Implementing and maintaining policies and procedures, systems and controls
    • Are they properly documented, regularly reviewed and updated?
    • Are they effective? How do you find out if something, somewhere has gone wrong?
    • Are good records being kept?
    • Testing the controls: internal and external audit
    • Monitoring, testing and reporting: staff, customers and transactions
    • Are unusual activities being identified and escalated?
    • Are you providing/receiving high quality MI or vanity metrics?
    • Once identified, are problems addressed in good time?
    • Does Compliance have enough resources and access to all information?
    • Controlling and influencing staff behaviours: fostering awareness and understanding.

    12.30 – Sanctions & Weapons Proliferation Essentials
    13.00 – Lunch

    14.00
    Casestudy: review of the lessons to be learnt from recent regulatory enforcement actions relating to cross-border “Mirror Trades”
    Do You Really Know Your Customer?
    • The customer relationship – the firm’s evolving responsibilities and liabilities
    • FATF Recommendations
    • Customer due diligence, transparency and beneficial ownership
    • New customer onboarding procedures
    • Who is the beneficial owner? Who is controlling your customer and its assets?
    • What is the purpose of the relationship?
    • Low risk customers and simplified due diligence
    • High risk customers and enhanced due diligence
    • Which customers are higher risk?
    • How can you check if you are dealing with a Politically Exposed Person?
    • Recognising that a low risk can become a higher risk
    • How do you verify the identity of individuals, companies, trusts and other customers?

    15.30 – Afternoon Tea
    16.00 – AFC Suspicion Reporting
    • What must you report?
    • When should you be suspicious?
    • Do you have reasonable grounds to suspect?
    • When must you report your suspicion? And to whom? What are the red flags?
    • Typologies: cyrptocurrencies – correspondent banking – terrorism – trade finance
    • Escalating findings from monitoring and surveillance
    • Internal and external reporting procedures
    • The offences of “tipping off” and prejudicing an investigation
    • Working with the national Financial Intelligence Units.

    17.00 – Close



    Day 3


    09.30
    Casestudy: review of lessons to be learnt from regulatory enforcement actions relating to AFC procedures
    Investigations, Enforcement and Litigation
    • When and what do you need to tell your regulators and law enforcement?
    • What are their powers and your responsibilities?
    • Avoiding pitfalls in conducting an internal investigation
    • Your governance: who is managing the investigation?
    • What happened? Who was involved?
    • Have you gathered all the evidence? Documentation, emails and interviews
    • Who needs to take legal advice?
    • Enforcement proceedings and litigation: the impact upon your business.

    10.30 – Fraud Essentials
    11.00 – Morning Coffee
    11.30
    Misuse of Information Essentials
    • What are Confidential Information and Inside Information?
    • When is and how long does information remain confidential?
    • Need to know: managing information flows internally and externally
    • Market sounding procedures
    • Managing conflicts of interest and maintaining effective Chinese Walls
    • Staff personal account dealing
    • The dangers of emails and instant communication
    • Data protection.

    False and Misleading Statements and Practices Essentials
    • What are proper standards of market conduct?
    • What are your responsibilities to the market?
    • Would you approve a transaction when the Front Office pushes the rules to the limit?
    • Market abuse – manipulation, front running, cornering, short selling and beyond
    • Protecting your firm against a rogue trader: unauthorised trading, position limit breaches
    • Advertising and promoting your business.

    Casestudy: review of lessons to be learnt from market conduct enforcement actions
    13.00 – Lunch
    14.00 – Are Human Beings Your Weakest Link?
    • Creating and maintaining a compliance culture
    • Senior Management and the “Tone from the Top”
    • Communicating a corporate culture and values to staff
    • Recruitment, terms of employment, compensation and discipline
    • The responsibilities of the line manager and staff supervision
    • Whistleblowing procedures.

    15.00 – Is Your Staff Training Any Good?
    • Do staff understand their regulatory obligations?
    • Are they aware of the risks in your business?
    • Are staff being regularly trained?
    • Conducting a risk-based training needs analysis
    • Maintaining induction and business line training programmes
    • Are you delivering engaging training tailored to the business line?
    • Train the trainer
    • Do you run enough classroom training?
    • The importance of keeping good records
    • Can you show that your training is effective?

    16.00 – Close

  • Our Tailored Learning Offering

    Do you have five or more people interested in attending this course? Do you want to tailor it to meet your company’s exact requirements? If you’d like to do either of these, we can bring this course to your company’s office. You could even save up to 50% on the cost of sending delegates to a public course and dramatically increase your ROI.

    If you want to run this course at a location convenient to you or if you want a completely customised learning solution, we can help.

    We produce learning solutions that are completely unique to your business. We’ll guide you through the whole process, from the initial consultancy to evaluating the success of the full learning experience. Our learning specialists ensure you get the maximum return on your training investment.

  • We have a combined experience of over 60 years providing learning solutions to the world’s major organisations and are privileged to have contributed to their success. We view our clients as partners and focus on understanding the needs of each organisation we work with to tailor learning solutions to specific requirements.

    We are proud of our record of customer satisfaction. Here is why you should choose us to help you achieve your goals and accelerate your career:

    • Quality – our clients consistently rate our performance ‘excellent’ or ‘outstanding’. Our average overall score awarded to us by our clients is nine out of ten.
    • Track record – we have delivered training solutions for 95% of worlds’ top 100 banks and have trained over 250,000 professionals.
    • Knowledge – our 150 strong team of industry specialist trainers are world leading financial leaders and commentators, ensuring our knowledge base is second to none.
    • Reliability – if we promise it, we deliver it. We have delivered over 20,000 events both in person and online, using simultaneous translation to delegates from over 180 countries.
    • Recognition – we are accredited by the British Accreditation Council and the CPD Certification Service. In an independent review by Feefo we scored 96% on service and 95% on product
This course can be run as an In-house or Tailored Learning programme

Instructor

  • Nicholas Walmsley

    Biography

    Nicholas Walmsley is a highly experienced regulatory, compliance and anti-financial crime training professional. Nicholas has been training financial services staff and senior management globally for thirty years. Until August 2017, Nicholas was global head of compliance, financial crime and risk culture training at Deutsche Bank and he previously held the same role at Dresdner Kleinworts. Nicholas is a qualified lawyer and was a litigation partner in a City of London banking law firm specialising in financial services regulatory compliance and enforcement. Working with the business lines, Nicholas has conducted global training needs analyses; designed training programmes; and developed engaging training solutions including classroom presentations, e-Learning courses, videos, and documentary materials.Nicholas has delivered classroom compliance training across the world including in Mauritius, Zimbabwe, South Africa, India, Malaysia, Singapore, Hong Kong SAR, Taiwan SAR, Tokyo, New York, Jacksonville, Toronto, Barbados, United Kingdom, France, Spain, Italy, Greece, Germany, Finland, Switzerland, Turkey and Russia.Nicholas started his career as a member of the Commonwealth Secretariat's Commercial Crime Unit with responsibility for providing training to Commonwealth governments to combat economic crime. Nicholas is an editorial board member of the Journal of Financial Compliance. Nicholas was Deputy Director of the annual Cambridge International Symposium on Economic Crime 2017–2018. Nicholas graduated in history and law from Jesus College, University of Cambridge.