• Money Service Businesses and Money Remitters (with Network)

    Some services provided by money service businesses and money remitters are attractive to criminals wanting to launder the proceeds of crime and to finance terrorism.

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Money Service Businesses and Money Remitters (with Network)

What are the ML/TF Risks?

The industry is extremely diverse, ranging from large international companies with numerous outlets worldwide to small, independent businesses in communities with population concentrations that do not necessarily have access to traditional banking services.

The range of products and services offered and the customer bases served, are equally diverse.

The sector facilitates the transfer of funds within and between countries, often outside the formal financial and banking system.

The Money Laundering and Terrorism Financing (ML/TF) risks associated with Money Service Businesses and Money Remitters include:

  • Due to the number of transactions and intermediaries each transaction does not always have a single coherent set of documentation which identifies the remittance chain;
  • Remittance businesses have not always been obliged to identify their customers and may receive instructions over the phone or other non-face to face means, so they may not always know for whom they are acting;
  • The use of intermediaries through a network and the possible consolidation of remittances into one sum means that money is coming in from many sources and no one person or organisation may have responsibility for knowing the identity of all the sources;
  • Management and oversight of the network, which may present varying degrees of risk; and
  • Network participants that use one or more additional networks, which conceals the full extent of activity to any one party.

Money service businesses and money remitters 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.
  • Implement adequate oversight over the network.

How can AML Accelerate help?

AML Accelerate, drawing on unparalleled expertise and real-world experience, has developed an AML/CFT Program Manual for money service businesses and money remittance businesses with networks.

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.

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