ECMS Consulting

ECMS Consulting Delivering high-quality Training and Consulting services in the area of AML/CTF & Regulatory Compliance

Our Company
We are comprised of experts in law, compliance, banking, insolvency and restructuring, with decades of experience, specialised training and successes in our fields. We work closely with other leading advisors to provide sophisticated and innovative solutions, decisive resolutions to our client’s challenges and fast ex*****on. We have been retained by financial institutions, multi-natio

nals, professional bodies, legal advisors, company directors and high net worth individuals, to advise on all types of anti-money laundering, compliance, recovery, restructuring and insolvency matters. We bring this wide-ranging experience to all our assignments and our clients can confirm our reputation as leading professionals in our areas of expertise. Our team is comprised of professionals with experience, expertise and knowledge

We deliver on our commitments
We do business competently and resourcefully
We have strong relationships with our partners and clients
We provide solutions you can trust

Training Seminar (CPD): The essentials of an on-going transaction monitoring programLocation: Live OnlineCPD Units: 6Dur...
27/11/2024

Training Seminar (CPD): The essentials of an on-going transaction monitoring program

Location: Live Online
CPD Units: 6
Duration: 6hrs
Language: English
HRDA Approved
Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI
Cost (with/without HRDA subsidy):
€60-€180

Dates: 11 & 12 December | 10:00-13:15

Registration information:
https://lnkd.in/dpdWP95r

Course Description - Aims of the seminar:
▪️ Understand the regulatory environment related to transaction monitoring.
▪️ Assess and categorize risks based on factors such as customer profiles, transaction patterns, and geographic considerations.
▪️ Understand the transaction behavior associated with different products and services.
▪️ Navigate and interpret transaction data.
▪️ Respond to alerts triggered by transactions exceeding predefined thresholds.
▪️ Analyze scenarios and recognize patterns.
▪️ Investigate flagged transactions.
▪️ Appreciate the importance of generating comprehensive reporting.

Seminar The Digital Operational Resilience Act. (DORA)https://www.ecms.cy/training-seminars/doraDuration: 3 hoursLocatio...
26/11/2024

Seminar The Digital Operational Resilience Act. (DORA)
https://www.ecms.cy/training-seminars/dora

Duration: 3 hours
Location: Live Online
CPD Units: 3
Language: English
Instructor: Nicolas Poumbourides LL.M, CAMS, ACSI
Cost: €120
Date: 4 December | 10:00-13:15

Course Description - Aims of the seminar:
▪️ Understand DORA regulation.
▪️ Acknowledge the importance of the ICT risk management.
▪️ Comprehend the principle of reporting major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the competent authorities.
▪️ Appreciate the importance of reporting of major operational or security payment-related incidents to the competent authorities.
▪️ Understand digital operational resilience testing.
▪️ Develop the program of information and intelligence sharing in relation to cyber threats and vulnerabilities
▪️ Conduct audit, testing and assessment of the third-party service providers.
▪️ Understand the requirements in relation to the contractual arrangements concluded between ICT third-party service providers and financial entities.

Training Seminar (CPD): The role of the anti-money laundering (AML) Compliance FunctionLocation: Live OnlineCPD Units: 6...
24/10/2024

Training Seminar (CPD): The role of the anti-money laundering (AML) Compliance Function

Location: Live Online
CPD Units: 6
Duration: 6hrs
Language: English
HRDA Approved
Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI
​
Cost (with/without HRDA subsidy): €60-€180
Dates: 20 & 21 November | 10:00-13:15

Registration information: https://bit.ly/the-role-of-the-anti-money-laundering-aml-compliance-function

Course Description - Aims of the seminar:
▪️ Understand AML regulations.
▪️ Identify money laundering risks.
▪️ Employ enhanced due diligence (CDD) on high risk clients.
▪️ Comprehend transaction monitoring.
▪️ Appreciate reporting obligations.
▪️ Apply AML policies and procedures to day-to-day operations.
▪️ Develop company guidelines for record-keeping.
▪️ Conduct audit, testing and assessment of the compliance programme.
▪️ Emphasize the need for effective collaboration and communication with all stakeholders.

Thank You, , for a Successful Training! Financial Literacy We would like to extend our heartfelt thanks to the CySEC -...
24/10/2024

Thank You, , for a Successful Training! Financial Literacy
We would like to extend our heartfelt thanks to the CySEC - Cyprus Securities and Exchange Commission for their active participation in the recent 2-day training program delivered in collaboration with Mrs. Elena Constantinou and ECMS Consulting Ltd.

The training program, titled "The Essentials of an On-Going Transaction Monitoring Program", covered a wide range of critical topics, including:

🔹 Identifying and mapping risks based on customer profiles, transaction patterns, and geographic considerations
🔹 Understanding client transactions and behavior associated with different products and services.
🔹 Navigating and interpreting transaction and behavior data.
🔹 Constructing rules in automated monitoring systems.
🔹 Responding to alerts triggered by transactions exceeding predefined thresholds.
🔹 Analyzing scenarios and recognizing patterns.
🔹 Investigating flagged transactions.
🔹 Appreciating the importance of generating comprehensive SARs/STRs.
🔹 The effectiveness of a rule-based vs. risk-based approach to transaction monitoring.
🔹 New technologies such as Perpetual KYC, Natural Language Processing, Robotic Process Automation (RPA), and Artificial Intelligence (AI) systems.

The commitment of to fostering a strong compliance culture, aligned with their supervisory responsibilities, was evident throughout the program. Their profound knowledge of the EU's applicable AML/CTF framework enriched the sessions, enhancing the learning experience for all participants.

We look forward to future opportunities of collaborating with and continuing to support their mission of maintaining a robust regulatory environment for all hashtag .

Training Seminar (CPD): The essentials of an on-going transaction monitoring programLocation: Live OnlineCPD Units: 6Dur...
17/10/2024

Training Seminar (CPD): The essentials of an on-going transaction monitoring program

Location: Live Online
CPD Units: 6
Duration: 6hrs
Language: English
HRDA Approved
Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI

Cost (with/without HRDA subsidy):
€60-€180
Dates: 6 & 7November | 10:00-13:15

Registration information:
https://lnkd.in/dpdWP95r

Course Description - Aims of the seminar:
▪️ Understand the regulatory environment related to transaction monitoring.
▪️ Assess and categorize risks based on factors such as customer profiles, transaction patterns, and geographic considerations.
▪️ Understand the transaction behavior associated with different products and services.
▪️ Navigate and interpret transaction data.
▪️ Respond to alerts triggered by transactions exceeding predefined thresholds.
▪️ Analyze scenarios and recognize patterns.
▪️ Investigate flagged transactions.
▪️ Appreciate the importance of generating comprehensive reporting.

Training (CPD) Seminar The Digital Operational Resilience Act. (DORA)https://bit.ly/advanced-debt-restructuringDuration:...
15/10/2024

Training (CPD) Seminar The Digital Operational Resilience Act. (DORA)
https://bit.ly/advanced-debt-restructuring

Duration: 3 hours
Location: Live Online
CPD Units: 3
Language: English
Instructor: Nicolas Poumpourides
Cost: €120

Dates:
13 November | 10:00-13:15
4 December | 10:00-13:15

Course Description - Aims of the seminar:
▪️ Understand DORA regulation.
▪️ Acknowledge the importance of the ICT risk management.
▪️ Comprehend the principle of reporting major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the competent authorities.
▪️ Appreciate the importance of reporting of major operational or security payment-related incidents to the competent authorities.
▪️ Understand digital operational resilience testing.
▪️ Develop the program of information and intelligence sharing in relation to cyber threats and vulnerabilities
▪️ Conduct audit, testing and assessment of the third-party service providers.
▪️ Understand the requirements in relation to the contractual arrangements concluded between ICT third-party service providers and financial entities.

Key Differences Between Technical and Effective Compliance in AML/CTFIn the context of Anti-Money Laundering (AML) and C...
02/10/2024

Key Differences Between Technical and Effective Compliance in AML/CTF

In the context of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance, technical compliance and effective compliance represent two distinct dimensions of how an institution meets regulatory requirements.

The term “technical compliance” derived from the FATF’s 2013-2022 Methodology for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT Systems, where assesses each member’s implementation of the FATF Recommendations and its actions to tackle money laundering, terrorist financing on an on-going basis.

But, how the technical –vs- effective compliance can be interpreted within an Institutions’ AML/CTF Compliance program?

1. Technical Compliance

Technical compliance refers to the formal, structural adherence to the laws, regulations, and guidelines set forth by governing bodies related to AML/CTF. It focuses on whether an institution has the necessary policies, procedures, and systems in place to comply with the specific requirements.

Characteristics of Technical Compliance:

Regulatory Framework Alignment: Ensuring that an institution’s policies, procedures, and systems meet the specific legal and regulatory standards. This includes being compliant with local and international regulations, such as the FATF recommendations, EU Directives, or National Laws.

▪️ Documented Policies: Having a written and structured AML/CTF program that outlines processes e.g. Know Your Customer (KYC), Customer Due Diligence (CDD), transaction monitoring, and reporting of suspicious activities.

▪️ Controls and Procedures: Setting up the necessary systems for screening customers, conducting risk assessments, filing Suspicious Activity Reports (SARs), and training employees.

▪️ Audits and Inspections: Demonstrating that the institution has the right paperwork, tools, and compliance frameworks in place when audited or inspected by regulators.

2. Effective Compliance

Effective compliance goes beyond merely meeting regulatory requirements on paper. It focuses on the real-world implementation and impact of AML/CTF Regulatory Framework, ensuring that the institution is not just compliant in paper, but also in substance.

Characteristics of Effective Compliance:

▪️ Implementation and Functionality: Ensures that AML/CTF procedures are actively preventing, detecting, and mitigating risks associated with money laundering and terrorist financing.
Outcome-Oriented: Emphasizes the actual results of compliance efforts, such as whether suspicious activities are being effectively identified and reported, or whether customers are appropriately risk-assessed.

▪️ Risk-Based Approach: Involves adapting AML/CTF measures based on the specific risks associated with different customer profiles, products, services, or jurisdictions. It is dynamic and adjusts to changing risk landscapes.

▪️ Continuous Improvement: Effective compliance systems are regularly reviewed, updated, and tested to improve their performance and respond to new challenges (e.g., emerging financial crimes typologies, changes in regulations).

▪️ Training and Awareness: Ensures that staff are not only trained in compliance procedures but also understand the rationale behind them and are proactive in identifying suspicious behavior.

By, Nicolas Poumpourides LL.M, CAMS, ACSI

Nicolas Poumpourides is a Legal & Compliance Expert with 25 years of demonstrated managerial experience in the legal, financial services & banking industries. He is currently located in Brussels, providing professional trainings and consulting on anti-money laundering and counter terrorist financing, as well on EU Financial Services Law through ECMS Consulting Ltd (https://www.ecms.cy/). He brings to his trainings a wealth of experience from being a lawyer, the Head of the legal & compliance department in a Financial Services firm and a compliance expert in a worldwide banking institution in Luxembourg.

Learn more about our upcoming Seminars:

🔸 Live Online Training Seminar (CPD): The role of the anti-money laundering (AML) Compliance Function

Location: Live Online
CPD Units: 6
Duration: 6hrs
HRDA Approved
Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI
Dates: 23 & 24 October | 10:00-13:15
20 & 21 November | 10:00-13:15

Registration link https://bit.ly/the-role-of-the-anti-money-laundering-aml-compliance-function

Course Description - Aims of the seminar:
▪️ Understand AML regulations.
▪️ Identify money laundering risks.
▪️ Employ enhanced due diligence (CDD) on high risk clients.
▪️ Comprehend transaction monitoring.
▪️ Appreciate reporting obligations.
▪️ Apply AML policies and procedures to day-to-day operations.
▪️ Develop company guidelines for record-keeping.
▪️ Conduct audit, testing and assessment of the compliance programme.
▪️ Emphasize the need for effective collaboration and communication with all stakeholders.

🔸 Training (CPD) Seminar: The Digital Operational Resilience Act. (DORA)
Duration: 3 hours

Location: Live Online

CPD Units: 3

Language: English

Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI

Cost: €120

Date: 16 October | 10:00-13:15

13 November | 10:00-13:15

4 December | 10:00-13:15

Registration information: https://lnkd.in/dctKXsXr

Course Description - Aims of the seminar:
▪️ Understand DORA regulation.

▪️ Acknowledge the importance of the ICT risk management.

▪️ Comprehend the principle of reporting major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the competent authorities.

▪️ Appreciate the importance of reporting of major operational or security payment-related incidents to the competent authorities.

▪️ Understand digital operational resilience testing.

▪️ Develop the program of information and intelligence sharing in relation to cyber threats and vulnerabilities.

▪️ Conduct audit, testing and assessment of the third-party service providers.

▪️ Understand the requirements in relation to the contractual arrangements concluded between ICT third-party service providers and financial entities.

23/09/2024

⚙ The duties & responsibilities of the , towards the AML/CTF Compliance Program.

➡ The First Line of Defense (1LoD) in Anti-Money Laundering ( ) and Counter-Terrorist Financing ( ) compliance is primarily responsible for managing and mitigating directly within the business functions. This line typically consists of front-line employees, business units, and operational staff who interact with customers and execute transactions.

➡ (Financial Crime Compliance) structures primarily consists of the , with the main duty of designing the policies, procedures and controls for the (implement) and the (internal audit) (review).

➡ Here are the key (and not exhaustive) duties of the 1LoD in the context of AML/CTF compliance:

1️⃣ Customer Due Diligence ( ) and Enhanced Due Diligence ( )

✅ Know Your Customer ( ): The 1LoD is responsible for collecting, verifying, and documenting customer information at the stage of customer . This includes understanding the nature and purpose of the customer's activities to assess their risk level and future inconsistencies and suspicion during the transaction monitoring.

✅ Risk Assessment: Perform the initial on customers to determine the customers’ risk level and if enhanced due diligence ( ) is necessary.

2️⃣ Transaction Monitoring

✅ Monitoring: Monitor transactions in real-time or in a post-transaction manner to detect potentially activities or . This includes flagging transactions that are inconsistent with a customer's known profile or that exhibit patterns indicative of /terrorist financing or breaches.

✅ Alert Handling: When suspicious activity is detected, the 1LoD must investigate and close the triggered alerts or these alerts to the appropriate 2LoD team for further investigation, if necessary.

3️⃣ Reporting Suspicious Activity

✅ Suspicious Activity Reporting ( ): Employees in the 1LoD are often the first to identify suspicious activities. Either from employees’ observations and reporting (manual) or through the automated transaction monitoring system (alerts).

4️⃣ Escalation and Collaboration (KPI’s)

✅ Escalation of Issues: In large world-wide Financial Institutions, usually the is located away from the headquarters (sometimes in a different country) or is out-sourced to a designated team. When potential AML/CTF concerns are identified, the should promptly escalate these to , which typically they cooperate under performance metrics ( ’s) subject to the terms of a Service Level Agreement ( ).

5️⃣ Controls Effectiveness Assessment

✅ Operational Effectiveness of : control effectiveness is assessed by , undertaking a focused self-assessment in accordance with the applicable regulatory mapping by the .

The Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA).If a cyber-attack on the...
20/09/2024

The Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA).

If a cyber-attack on the Cyprus Land Registry or the University of Cyprus could cause the temporary paralyzing of a large segment of the Cyprus economic activity, imagine how crippling a cyber- attack on a significant Banking Institution could be.

The Regulation (EU) 2022/2554 on digital operational resilience for the financial sector (DORA) targets businesses and organizations that operate in the financial sector as well as critical third-parties that offer services related to information and communication technology (ICT) to financial entities. Financial entities will be expected to be compliant by Q4 2024 and DORA will be binding at the start of 2025. How is your organization doing with their compliance with DORA?

In the digital age, ICT keeps our economies running. Increased digitalization and interconnectedness also amplify ICT risk, making society as a whole, and the financial system in particular, more vulnerable to cyber threats or ICT disruptions.

DORA Regulation promotes a set of principles that facilitate the overall structure of ICT risk management (identification, protection and prevention, response and recovery, learning and evolving, as well as communication).

To keep pace with an evolving cyber threat landscape, financial entities should maintain updated ICT systems that are reliable and capable, guaranteeing the processing of data required for their services.

In order to maintain full control over ICT risk, financial entities need to have comprehensive capabilities to enable a strong and effective ICT risk management, as well as specific mechanisms and policies for handling and reporting ICT-related incidents. Likewise, financial entities should have policies in place for:
▪️ the testing of ICT systems,
▪️ managing ICT third-party risk.

Financial entities should regularly test their ICT systems and staff having ICT-related responsibilities with regard to the effectiveness of their preventive, detection, response and recovery capabilities, to uncover and address potential ICT vulnerabilities.

Financial entities should apply a proportionate approach to the monitoring of risks emerging at the level of the ICT third-party service providers, by:
▪️ duly considering the nature, scale, complexity and importance of ▪️ their-related dependencies,
continuously evaluating the criticality or importance of the services, processes or functions subject to the contractual arrangements and, ultimately, carefully assessing any potential impact on the continuity and quality of financial services at individual and at group level, as appropriate.

To enhance supervisory awareness of ICT third-party dependencies, and with a view to further support the Oversight Framework established by the Regulation, all financial entities should be required to maintain a register of information with all contractual arrangements related to all services provided by ICT third-party service providers.

Is your organization adequately prepared to review and amend all ICT third-party service contracts to ensure the coverage of the key contractual provisions as provided for in the Regulation (complete descriptions of functions and services, locations where such functions are provided and where data is to be processed)?

DORA provides the opportunity and the guidelines to significantly improve the digital operational resilience of the Cyprus financial sector and keep the country in line with competitive financial markets. How can DORA also help your own organization not only stay resilient but also, to thrive?

By, Nicolas Poumpourides, LL.M, CAMS, ACSI

Nicolas Poumpourides is a Legal & Compliance Expert with 25 years of demonstrated managerial experience in the legal, financial services & banking industries. He is currently located in Brussels, providing professional trainings and consulting on anti-money laundering and counter terrorist financing, as well on EU Financial Services Law through ECMS Consulting Ltd (https://www.ecms.cy/). He brings to his trainings a wealth of experience from being a lawyer, the Head of the legal & compliance department in a Financial Services firm and a compliance expert in a worldwide banking institution in Luxembourg.

Learn more about our upcoming Seminars:

🔸 Training (CPD) Seminar: The Digital Operational Resilience Act. (DORA)

Duration: 3 hours
Location: Live Online
CPD Units: 3
Language: English
Instructor: Nicolas Poumpourides LL.M, CAMS, ACSI
Cost: €120
Date:16 October | 10:00-13:15

Registration information: https://lnkd.in/dctKXsXr

Course Description - Aims of the seminar:
▪️ Understand DORA regulation.
▪️ Acknowledge the importance of the ICT risk management.
▪️ Comprehend the principle of reporting major ICT-related incidents and notifying, on a voluntary basis, significant cyber threats to the competent authorities.
▪️ Appreciate the importance of reporting of major operational or security payment-related incidents to the competent authorities.
▪️ Understand digital operational resilience testing.
▪️ Develop the program of information and intelligence sharing in relation to cyber threats and vulnerabilities.
▪️ Conduct audit, testing and assessment of the third-party service providers.
▪️ Understand the requirements in relation to the contractual arrangements concluded between ICT third-party service providers and financial entities.

What is the difference between AML/CTF screening and monitoring?AML (Anti-Money Laundering) and CTF (Counter-Terrorism F...
16/09/2024

What is the difference between AML/CTF screening and monitoring?

AML (Anti-Money Laundering) and CTF (Counter-Terrorism Financing) screening and monitoring are both critical components of financial institutions' efforts to detect and prevent illicit activities. While they are related, they serve different purposes and are applied at different stages of the process. Here's a breakdown of their differences:

AML/CTF Screening
▪️ Purpose: Screening is the initial step used to identify potential risks associated with clients or transactions. It focuses on e.g. verifying the identities of customers or Beneficial Owners against various lists and databases to ensure they are not associated with illegal activities, such as money laundering or terrorism financing.

▪️ When It Occurs: Screening typically occurs at the on-boarding stage (when a customer or a legal entity is first engaging with the financial institution) but can also be done periodically during the customer relationship.

Key Activities:
▪️ Sanctions Screening: Checking customers against global sanctions lists (e.g., OFAC, UN sanctions).
▪️ PEP Screening: Identifying if a customer is a Politically Exposed Person (PEP), which may indicate a higher risk of involvement in corruption or other illicit activities.
Adverse Media Screening: Searching for negative news or reports about a customer that may indicate a higher risk profile.
Outcome: The outcome of screening is typically a pass/fail decision, which may trigger further due diligence if any red flags are identified.

AML/CTF Monitoring
▪️ Purpose: Monitoring is an on-going process designed to detect suspicious activities during the course of the business relationship. It focuses on observing the behavior and transactions of customers to identify patterns that may indicate money laundering, terrorism financing, or other illegal activities.
▪️ When It Occurs: Monitoring occurs on an on-going basis throughout the customer business relationship.

Key Activities:
▪️ Transaction Monitoring: Analyzing customer transactions in real-time or post-transaction manner, to identify unusual or suspicious patterns, such as large or unusual transfers, multiple small transactions (structuring), or transactions in high-risk jurisdictions.
▪️ Behavioral Monitoring: Observing inconsistencies in customer behavior that may indicate increased risk, such as a sudden overflow in transaction volume or changes in the type of transactions conducted.
▪️ Case Management: When suspicious activity is detected, it is escalated for further investigation, and potentially reported to regulatory authorities (e.g., through a Suspicious Activity Report, or SAR).
▪️ Outcome: The outcome of monitoring is typically the identification of suspicious activities that require further investigation. This may lead to the filing of regulatory reports or other compliance actions.

Learn more about our upcoming Seminars:

🔸️Live Online Training Seminar (CPD): The essentials of an on-going transaction monitoring program

HRDA Approved
Instructor: Nicolas Poumbourides LL.M, CAMS, ACSI
Dates:
9 & 10 October | 10:00-13:15
6 & 7 November | 10:00-13:15
11 & 12 December | 10:00-13:15
⬇️
Registration information: https://bit.ly/the-essentials-of-an-on-going-transaction-monitoring-program

How to effectively design your AML/CTF policies and procedures?You are in front of the selection panel during the final ...
16/09/2024

How to effectively design your AML/CTF policies and procedures?

You are in front of the selection panel during the final stage of an interview for the position of the Compliance Officer in a newly established Payment Institution and one of the members of the selection panel is asking you the following question:

How to design your organization’s AML/CTF policies and procedures?

1. Understand Regulatory Requirements
▪️ Identify Applicable Laws: Research and understand the AML/CTF laws and regulations that apply to your jurisdiction. This may include local, regional, and international regulations such as the EU AML Directives, or FATF Recommendations.

▪️ Example: Thoroughly review and understand the competent Supervisory Authority (e.g. FinCEN) Directives, Circulars and guidance.

2. Conduct a Risk Assessment
▪️ Identify Risk Factors: Identify potential risks related to money laundering and terrorist financing within your organization. These could be related to the types of customers you serve, the countries you operate in, the products and services you offer, and the delivery channels you use. Then, assess the level of risk associated with each factor. This will help in prioritizing areas that need more stringent controls.

▪️ Example: identify all the inherent risks prior the application of any controls, where the organization is exposed according to the applicable risk factors (clients, geography, products/services)

3. Define Clear Objectives
▪️ Purpose and Scope: Clearly define the purpose and scope of your AML/CTF policies. State what the policies aim to achieve, such as preventing money laundering, complying with legal obligations, and protecting the organization’s reputation. Outline which Unit or Function is responsible for implementing and maintaining the AML/CTF policies and procedures within your organization.

▪️ Example: identify the areas of potential vulnerabilities within a certain function (e.g. client on-boarding).

4. Start drafting the Key Policies of your organization
▪️ Customer Due Diligence (CDD) and Know Your Customer (KYC)
▪️ Customer Acceptance policy
▪️ Transaction Monitoring and suspicious activity management
▪️ Record Keeping
▪️ Reporting

5. Design the Internal Controls to be implemented
▪️Make functional your policies and procedures: Controls are programs, policies or activities put in place by the Financial Institutions to protect against the materialisation of a ML risk or to ensure that potential risks are promptly identified and mitigate to an acceptable level.

▪️Example: in collaboration with the business line and the client-facing line managers, assess the Internal Control Environment needed to be implemented.

Learn more about our upcoming Seminars:

🔸️Live Online Training Seminar (CPD): The role of the anti-money laundering (AML) Compliance Function

HRDA Approved
Instructor: Nicolas Poumbourides LL.M, CAMS, ACSI

Dates: 23 & 24 October |10:00-13:15

Registration information: https://bit.ly/the-role-of-the-anti-money-laundering-aml-compliance-function

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