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Course details

Dates are currently being finalised. Get in touch to find out more
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Trade Based Money Laundering (TBML) & Sanctions

  • Introduction

    Banks who have failed to have adequate AML and sanctions compliance programmes and training in place have incurred penal fines, reputational damage and faced the potential loss or suspension of their ability to operate in certain currency markets or jurisdictions

    This two-day workshop is focused on the associated AML and sanctions compliance risks in Trade Finance. It has been designed for correspondent bankers, trade operational and sales personnel and compliance officers to enable them to identify compliance risk zones in each of these product areas. The course uses a range of typologies, exercises and case studies to develop the understanding of delegates in a practical and engaging way across a range of scenarios

    Training structure and methodology


    Compliance risk; the compliance risks (AML and sanctions) associated with international trade will be described and how the use of red flags can identify suspicious activity

    Trade products; the vulnerability of correspondent banking and trade products to abuse will be explained together with their compliance risk profile. Suspicious activity red flags will be highlighted and the ways to structure these trade products to reduce the risk of abuse.

    Each will be described in terms of its operation and compliance risk profile through presentational slides, diagrams and examples

     

    Case studies*; these will provide an opportunity for the delegates to consider relationships and transactions and identify the key risk compliance features, areas of due diligence and enhanced due diligence, and further information required to make a risk-based assessment

     

    Each delegate will receive a workbook containing the presentational slides and supporting material


    *The case studies and exercises described are provided for indicative purposes only. The trainer reserves the right of discretion to vary the selection of case studies covered in the classroom depending upon the background, experience and key learning objectives of the delegates in attendance and classroom time availability



    Objectives


    By attending this training course, the delegates will understand the function, parties, role, operation, compliance risks and red flags of:

    • Correspondent banking;
      Its fundamental role in the movement of international money and trade flows
      The characteristics which result in high compliance risk
    • SWIFT messages:
      Vulnerability to compliance risk
    • Trade finance products; letters of credit, documentary collections and bank aval
    • Trade related guarantees, transferable guarantees and standby letters of credit
    • Pre-export finance
    • Trade receivables purchase finance
  • Day One

    Introduction to compliance risk
     The nature of compliance risk in cross border transactions
     Why cross border transactions are a target for abuse

    Anti-money laundering (“AML”)

     The risk-based approach
     An overview of the stages; placement, layering, integration
     Suspicious transactions

    Sanctions violation

     Nature, purpose and impact of sanctions
     Trade embargo and financial sanction (to include export licensing and dual-use goods)
     Global reach; the importance and implications of the currency of payment
     The compliance risk exposure of US dollar transfers
     Bank exposure
     Risk assessment

    The cost of non-compliance

     Case study; AML and sanctions violation

    Correspondent banking

     Introduction to correspondent banking; description, parties, function and operation
     The vital role of correspondent banking in cross border money and trade flows
     Gateway to compliance risk
     Correspondent banking infrastructure:
    o Message authentication;
    o Nostro and vostro accounts
    Exercise; due diligence and risk considerations
     Correspondent banking; key areas of compliance risk
     Recent market trends in respect of compliance challenges

    Compliance risk; SWIFT

     SWIFT message abuse:
    o Omitting information
    o Message stripping
     Key compliance risk zones:
    o Originator; ownership, jurisdiction
    o Beneficiary; ownership, jurisdiction
    o Nature and value of transaction – ordinary course of business?
    o Screening – designated persons – sanctioned countries?

    Trade based money laundering (TBML)

     Common methods of TBML
    Typologies; misrepresentation in price, nature of goods and multiple invoicing

    Documentary collections
     Description and operation
     Parties
     Types; DP, DA, Bank Aval
     Compliance risk assessment and exposure
     Product compliance risk profile

    Case study; purchase of an avalised bill of exchange. Delegates will be required to undertake due diligence and identify further information required to undertake a compliance risk-based assessment of the transaction

    Letters of credit
     Description and operation
     Parties
     Key aspects
     Example transaction
     Trade documentation; compliance risk
     Sanctions clausing
     Fragmented bank roles; compliance risk exposure
     LC confirmation; financial engagement and responsibility

    Case study; the assessment of a potential money laundering cross border letter of credit transaction requiring delegates to identify key compliance risk issues and further information required to make a risk-based assessment

     Compliance risk assessment; issuance, presentation of documents, payment:
    - Issuing bank
    - Advising bank
     Product compliance risk profile

    Case study; delegates will be asked to identify unusual features of a letter of credit request and identify the red flag suspicious activity characteristics

    Day Two

    Case study; delegates will consider a request to issue a letter of credit which is not in the ordinary course of business of the applicant and to identify the nature of the underlying transaction

    Transferable letters of credit
     Description and operation
     Parties
     Transfer changes
     Product compliance risk profile

    Case study; the assessment of a suspicious transferable letter of credit transaction. The delegates will be required to identify any unusual features, to identify key compliance risk issues and further information required to make a risk-based assessment

    Synthetic letters of credit
     Description and operation
     Parties
     Product compliance risk profile

    Case study; delegates will examine a transaction and identify the compliance risk aspects

    Standby letters of credit
     Description and operation
     Parties
     Example transaction; commercial standby credit
     Claim documentation; exposure to compliance risk
     Its use in money laundering
     Product compliance risk profile

    Case study; delegates will be required to consider the course of action resulting from a suspicious claim under a standby LC and how the use of this product for money laundering can be reduced

    Trade related demand guarantees
     Description, operation and parties
     The nature and compliance risk of “on demand” unconditional guarantees
     Key aspects
     The types and use of trade guarantees:
    o Advance payment (working example)
     Transferable guarantees and associated compliance risks
     An appreciation of URDG 758
     Product compliance risk profile

    Case study; the delegates will consider the compliance risk aspects of a request to issue a transferable letter of guarantee and the further information required to undertake due diligence. The delegates will be required to identify any unusual aspects and consider the course of action

    Day Three

    Receivables finance

     Parties
     Financing open account transactions; compliance risk exposure
     Forms of receivables finance:
    o Selected debt purchase
    o Factoring
     Product compliance risk profile

    Case study; the delegates will be required to consider key aspects of due diligence on a request to purchase an invoice

    Structured trade & commodity finance

     Introduction; description, function and operation
     Key compliance risk zones (in addition to those listed under trade finance)

    Pre-export finance Description and operation
     Parties
     Compliance risk & due diligence

    Typology; the use of commodity-based pre-payment to disguise the movement of illicit funds

     Product compliance risk profile

    Case study; delegates will consider the compliance risk aspects of a commodity-based trade finance transaction. The delegates will be required to construct a pre-export trade finance solution to validate the goods and control the release of payment

    SUMMARY/CONCLUSION

    Delegate pack only

    COMPLIANCE RISK FRAMWORK

    RED FLAGS
     Trade based money laundering
     Sanctions

    SOURCES OF REFERENCE
  • 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

  • Stephen Jones

    Biography

    Stephen Jones is a highly experienced trade finance practitioner with over 40 years of trade finance expertise (35 of which was gained in the corporate banking environment). He has held senior trade positions in Lloyds Bank, NatWest and RBS.Stephen was the first in NatWest Corporate to win, structure and execute a multi-million pound limited recourse receivables finance structure for a new to bank major client. The structure used a syndicate of private insurers to transfer buyer and political risk. This resulted in the successful provision of 3 years trade credit to a buyer in Africa and off balance sheet receivables finance to the exporterDuring his time as Regional Head of International Trade, Stephen overviewed and structured his team’s trade finance submissions to the credit department achieving a 97% credit approval success rate over a 4 year periodStephen continues to work as a trade finance practitioner and consultant advisor handling trade transactions and letters of credit thus enabling him to deliver training material relevant to today’s market.

Venue

London

The course will take place at a Central London hotel.

The map attached details some of our most frequently used venues

If you need help booking accommodation for your visit, please contact accommodation@euromoney.com and one of our partners will help you get the best rate possible.