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Questions and Answers
What is the main objective of layering in the money laundering process?
What is the main objective of layering in the money laundering process?
What is the purpose of customer due diligence in AML compliance?
What is the purpose of customer due diligence in AML compliance?
What is one of the requirements for photocopying identification documents?
What is one of the requirements for photocopying identification documents?
What is the deadline for submitting quarterly reports?
What is the deadline for submitting quarterly reports?
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What is the purpose of integration in the money laundering process?
What is the purpose of integration in the money laundering process?
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What is the time period for the submission of a valid Power of Attorney (POA)?
What is the time period for the submission of a valid Power of Attorney (POA)?
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What is required for a Power of Attorney (POA) issued overseas?
What is required for a Power of Attorney (POA) issued overseas?
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What is an example of a potentially higher-risk situation?
What is an example of a potentially higher-risk situation?
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What is required for a Politically Exposed Person (PEP) transaction?
What is required for a Politically Exposed Person (PEP) transaction?
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What is a condition for a valid Power of Attorney (POA)?
What is a condition for a valid Power of Attorney (POA)?
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Study Notes
Money Laundering
- Placement refers to the physical disposal of cash proceeds, e.g., purchasing an insurance policy.
- Layering involves separating the proceeds of a crime from its source through complex financial transactions.
- Integration involves placing the laundered proceeds back into the economy, e.g., through the proceeds from a surrendered policy.
Legal Obligations
- Appointment of a Compliance Officer
- Customer Due Diligence (CDD)
- Enhanced Due Diligence (EDD)
- Internal Controls and Systems
- Training and Maintaining a Register of attendees
- Ongoing Monitoring/Auditing
- Record Keeping
- Submission of Quarterly reports due by the 15th after every Quarter ends
Customer Due Diligence (CDD)
- Identification of customers and verification of their identity
- Identifying beneficial owners who are not the customer and documenting them properly
- Understanding the nature of the economic activity that gave rise to the need for insurance
- Assessing product characteristics to ensure low risk of money laundering
- Having a process to escalate CDD if there are concerns
Standard Due Diligence Procedures
- Completing a Know Your Client Form (Client Verification Form)
- Obtaining Identification Documents
- Obtaining Proof of Address
Identification Procedures
- Photocopying both sides of an ID card/driver’s licence or the bio-data page of a passport
- Ensuring documents are valid and photocopied clearly
- Stamping/verifying documents and certifying them with a legible name
Proof of Address (POA)
- Submitting a POA within a 6-month period with a clearly visible date
- Using an internal letter as alternative proof of address if necessary
- Ensuring POA is stamped/verified by the receiving officer
Power of Attorney (POA)/Beneficiary
- Following the same procedures as ID and Proof of Address
- Ensuring POA gives authority to sign and execute contracts
- Updating POA issued overseas at the Registry before acceptance
Enhanced Due Diligence (EDD)
- Applying to Politically Exposed Persons (PEPs), non-resident customers, money and wire transfer services, and cash-intensive businesses
- Conducting EDD measures if Standard CDD inquiry leads to high-risk determination
Enhanced Due Diligence Process
- Obtaining details of the source and origin of funds or recent financial statements
- Obtaining details of relationships between signatories and beneficial owners of insured property
- Approving transactions with PEPs by senior Management
- Informing the Compliance Officer of new PEPs
Politically Exposed Persons (PEPs)
- A PEP is an individual who holds or has held a prominent public function, including family members or close associates
- PEPs include Heads of State, Senior Politicians, Judicial or Military Officials, and Senior Executives of State-Owned Corporations
Sanctions under AML Act No. 13 of 2009
- Sanctions can be imposed by the Bank of Guyana (BOG)
- Sanctions include administrative penalties, written warnings, and other measures
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Description
This quiz covers the concepts of placement, layering, and integration in the context of money laundering and financial crimes.