Risks of Violating Money Laundering Laws

Opportunity for criminals to move money without exposing their identity = Lack of fully verifying sender/receiver identities in money transfer services Difficulty in tracing origin of money in international transactions = Facilitation of illicit cash flows by mixing with legitimate transactions Complication in detecting suspicious transactions when crossing national borders = Challenge of enforcing strict rules and regulations in certain regions/countries Challenge in identifying suspicious patterns among large volume transactions = Processing large volumes and frequent transactions by Money Transfer Organizations

Opportunity for criminals to move money without exposing their identity = Lack of fully verifying sender/receiver identities in money transfer services Difficulty in tracing origin of money in international transactions = Facilitation of illicit cash flows by mixing with legitimate transactions Complication in detecting suspicious transactions when crossing national borders = Challenge of enforcing strict rules and regulations in certain regions/countries Challenge in identifying suspicious patterns among large volume transactions = Processing large volumes and frequent transactions by Money Transfer Organizations

Lack of fully verifying sender/receiver identities in money transfer services = Opportunity for criminals to move money without exposing their identity Facilitation of illicit cash flows by mixing with legitimate transactions = Difficulty in tracing origin of money in international transactions Challenge of enforcing strict rules and regulations in certain regions/countries = Complication in detecting suspicious transactions when crossing national borders Processing large volumes and frequent transactions by Money Transfer Organizations = Challenge in identifying suspicious patterns among large volume transactions

Three lines of defense = Role division between operational staff, policy makers, Compliance risk management, and auditors Transaction monitoring triggers = Business rules triggering investigation for high-risk transactions Financial Intelligence Unit (FIU) reports = Reports on transactions made in accordance with requirements Customer research training = Training employees to identify situations requiring further investigation

High-profile transactions = Transferring more than 3,000 euros to Peru High profile customer profiles = Senders or recipients being unlisted foundations Unusual items in Money Transfer Organizations = Related to high-profile transactions, customer profiles, and agent profiles Transaction monitoring issues = Inadequate maintenance and updating of business rules

Lack of effective control over transactions = Resulting from not enforcing strict rules in certain regions or countries Late or incomplete FIU reports = Non-compliance with reporting requirements Insufficiently trained employees = Failures in identifying suspicious activities and triggering further investigations Guidance documents from central banks = Providing tips on setting up processes for Money Laundering Prevention Act compliance

Frequent review of business rules = To identify unusual or suspicious transactions effectively Division of roles in MTOs = To separate operational staff, policy makers, compliance risk management, and auditors Alertness during customer interactions = Asking customers about the purpose of money being transferred Accounting for unusual events in MTOs = Regarding high-profile transactions, customer profiles, and agent profiles

Importance of customer profile formation = Easier at traditional banks due to higher transaction volumes Issuance of guidance documents by central banks = For assisting organizations in implementing Money Laundering Prevention Act processes Nederlandsche Bank's role in supervision = Overseeing Money Transfer Organizations incorporated in the Netherlands Customer transaction pattern identification = Easier at traditional banks due to more extensive onboarding processes