• Foreign Exchange

    Some services provided by foreign exchange dealers are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Foreign Exchange

What are the ML/TF Risks?

The industry is extremely diverse, ranging from large international companies with numerous outlets worldwide to small, independent businesses.

The sector facilitates the conversion of one currency to another, either in physical form or electronically.

The Money Laundering and Terrorist Financing (ML/TF) risks associated with foreign exchange dealers include:

  • Foreign Exchange dealers may also be part of a transfer of funds overseas;
  • Foreign Exchange businesses have not always been obliged to identify their customer; and
  • Customers may receive instructions over the phone or other non-face-to-face means, so they may not always know for whom they are acting.

Foreign exchange dealers must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures as a critical first step in complying with AML/CFT laws.

What are the AML/CFT obligations?

In developing responses to obligations under AML/CFT laws and regulations the following steps must be undertaken:

  • Conduct a Money Laundering and Terrorism Financing Risk Assessment;
  • Develop an AML Program that is proportionate to ML/TF Risks;
  • Establish effective Board and Senior Management oversight of the AML/CFT Program;
  • Appoint an AML Compliance Officer;
  • Establish a Customer Due Diligence (CDD) Program including collection and verification of know your customer (KYC) information including Enhanced and Ongoing CDD controls;
  • Implement a ML/TF Risk Awareness Training Program for staff;
  • Implement a monitoring program to identify unusual and possibly suspicious customer activity, transactions and behaviour;
  • Establish a process to report suspicions and other activity specified by AML/CFT law and regulation;
  • Establish Record-keeping controls; and
  • Maintain the ML/TF Risk Assessment and the AML Program as the business and risks change.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for foreign exchange businesses.

Our solutions deliver all the foundational AML/CFT materials including a ML/TF Risk Assessment, an AML/CFT Program, CDD Standards, and an AML Operating Manual, which you can tailor to your specific needs, ensuring your AML/CFT controls are commensurate with your business.

Who has used AML Accelerate in this sector?


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Client success stories…

AML Accelerate platform has allowed us to update our Risk Assessment, adapt our existing AML Program and create a foundation for a truly global AML compliance regime. The intuitive and agile nature of the platform has also meant that the speed of creation has not compromised our ability to take a detailed and analytical approach while building such an important component in our Risk management framework.

Stu Hallows, Chief Operating Officer – NexPay

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