Podcast
Questions and Answers
In the context of the provided information, when should a red flag noted during due diligence procedures be escalated to the Operations Director and Risk & Compliance?
In the context of the provided information, when should a red flag noted during due diligence procedures be escalated to the Operations Director and Risk & Compliance?
Which of the following is NOT mentioned as a due diligence procedure?
Which of the following is NOT mentioned as a due diligence procedure?
What type of third party requires the approval of the Operations Director and Risk & Compliance before engagement?
What type of third party requires the approval of the Operations Director and Risk & Compliance before engagement?
Which of the following processes should be completed before engaging a third party?
Which of the following processes should be completed before engaging a third party?
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Based on the provided information, what is the primary objective of due diligence procedures?
Based on the provided information, what is the primary objective of due diligence procedures?
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What has increased the risk of title fraud in real estate?
What has increased the risk of title fraud in real estate?
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Which of the following is NOT a reason why criminal syndicates are drawn to the property market for money laundering?
Which of the following is NOT a reason why criminal syndicates are drawn to the property market for money laundering?
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What is the primary focus for the Crane Capital Risk & Compliance Training in 2025?
What is the primary focus for the Crane Capital Risk & Compliance Training in 2025?
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What is a red flag indicator that could suggest money laundering in real estate?
What is a red flag indicator that could suggest money laundering in real estate?
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What is the primary focus of the Third Party Risk Management Policy?
What is the primary focus of the Third Party Risk Management Policy?
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What is a potential consequence of increased rental application fraud?
What is a potential consequence of increased rental application fraud?
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Which of the following is NOT explicitly mentioned as a key focus area for the training?
Which of the following is NOT explicitly mentioned as a key focus area for the training?
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What is the significance of 'Reinforce Compliance Commitment' in the training's key focus?
What is the significance of 'Reinforce Compliance Commitment' in the training's key focus?
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Which of the following is NOT explicitly mentioned as a focus area for Crane Capital in 2025?
Which of the following is NOT explicitly mentioned as a focus area for Crane Capital in 2025?
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Which type of real estate is particularly vulnerable to rental fraud?
Which type of real estate is particularly vulnerable to rental fraud?
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What type of global watchlists are mentioned in the context of Customer Due Diligence?
What type of global watchlists are mentioned in the context of Customer Due Diligence?
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What is a red flag suggesting potential money laundering in a real estate transaction?
What is a red flag suggesting potential money laundering in a real estate transaction?
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What is the objective of 'Adapting to Evolving Risks' in the 2025 training?
What is the objective of 'Adapting to Evolving Risks' in the 2025 training?
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Why is 'Strengthening Internal Controls' a key focus of the 2025 training?
Why is 'Strengthening Internal Controls' a key focus of the 2025 training?
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How can criminals use stolen identities in real estate fraud?
How can criminals use stolen identities in real estate fraud?
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What is the purpose of the Whistleblower Protection policy?
What is the purpose of the Whistleblower Protection policy?
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What is the purpose of 'Foster a Culture of Accountability' within the training?
What is the purpose of 'Foster a Culture of Accountability' within the training?
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Why is money laundering through real estate considered relatively easy for criminals?
Why is money laundering through real estate considered relatively easy for criminals?
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What is the purpose of the Anti-Fraud, Corruption, Money Laundering and Terrorism Financing Policy?
What is the purpose of the Anti-Fraud, Corruption, Money Laundering and Terrorism Financing Policy?
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Which of the following is an example of a cybercrime threat mentioned in the content?
Which of the following is an example of a cybercrime threat mentioned in the content?
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What is the relationship between 'Business Continuity and Crisis Management' and 'Incident Reporting' in this training?
What is the relationship between 'Business Continuity and Crisis Management' and 'Incident Reporting' in this training?
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According to the content, what is the significance of the growing digitization of the financial services sector?
According to the content, what is the significance of the growing digitization of the financial services sector?
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Based on the information provided, what could be a potential topic covered under 'Third Party Risk Management Program'?
Based on the information provided, what could be a potential topic covered under 'Third Party Risk Management Program'?
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How do financial institutions plan to enhance their cyber resilience in 2025?
How do financial institutions plan to enhance their cyber resilience in 2025?
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Which of the following is NOT a step in the incident closing process?
Which of the following is NOT a step in the incident closing process?
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What is the primary purpose of the Post Incident Review?
What is the primary purpose of the Post Incident Review?
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What is the final step in the incident closing process?
What is the final step in the incident closing process?
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When should communication plans be tailored?
When should communication plans be tailored?
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What is the purpose of meeting with the WSIB's Director of Operations and Investment Operational Due Diligence Officer?
What is the purpose of meeting with the WSIB's Director of Operations and Investment Operational Due Diligence Officer?
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What is the primary purpose of a password vault?
What is the primary purpose of a password vault?
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What is NOT a key aspect of strong password policies?
What is NOT a key aspect of strong password policies?
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Which of the following is an example of secure Wi-Fi practice?
Which of the following is an example of secure Wi-Fi practice?
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What is the purpose of incident response and recovery plans in cybersecurity?
What is the purpose of incident response and recovery plans in cybersecurity?
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What is a key aspect of governance and risk management in cybersecurity?
What is a key aspect of governance and risk management in cybersecurity?
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Which of the following is a key component of access control and identity management?
Which of the following is a key component of access control and identity management?
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What is the purpose of implementing a zero-trust architecture in cybersecurity?
What is the purpose of implementing a zero-trust architecture in cybersecurity?
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What is the importance of regular software updates in cybersecurity?
What is the importance of regular software updates in cybersecurity?
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Study Notes
Crane Capital Risk & Compliance Training
- Date: February 2025
-
Agenda:
- 2025 Crane's Key Risk & Compliance Focus
- Policies, Procedures and Guidelines
- Third Party Risk Management Program
- Anti-Fraud, Corruption, Money Laundering and Terrorism Financing
- Data Privacy and Cybersecurity Hygiene
- Business Continuity and Crisis Management
- Incident Reporting
- Quiz
- Closing Remarks
2025 Crane's Key Risk & Compliance Focus
- Reinforce Compliance Commitment
- Foster a Culture of Accountability
- Strengthen Internal Controls
- Adapt to Evolving Risks
- Enhance Crisis Management and Resilience
- Cybersecurity and Data Protection
Third Party Risk Management Program (TPRM) - Lifecycle
- Onboarding: Risk Assessment and Due Diligence, Procurement and Sourcing, Vendor Creation
- Ongoing: Performance Monitoring, Re-assessment and Due Diligence, Renewals, Vendor Maintenance, Governance Oversight and Accountability, Documentation, and Reporting, Independent Review
- Offboarding: Termination, Exit Strategy, Third Party Closure, Vendor Monitoring
Third Party Risk Management (TPRM) - Workflow
- Third Party (Non-Exhaustive List): Joint Venture Partners, Outsourced Service Providers, Commercial Agents/Sales Representatives, Consultants/Advisors, Contractors/Sub-Contractors, Vendors/Suppliers of Services, Insurance Brokers, Service Providers
- Third Party Assessment - Determine whether a service provider is already provided by Crane Capital, Outsourcing.
- Applicable Due Diligence Policies and Procedures- Outsourcing Policy, Outsourcing and Materiality Assessment, Procurement Policy, Vendor Management Policy, Supplier Code of Conduct.
- Tools: Online Adverse News Search, Initial Due Diligence Questionnaire, Outsourced Service Provider Assessment, Ongoing Performance Monitoring, Third Party Risk Rating and Due Diligence, etc.
- Other Relevant Risk and Compliance Requirement: Conflicts of Interest Declaration, Related Party Transactions, Non-disclosure agreements (NDA).
Money Laundering Red Flags Indicator in Real Estate
- Use of Third Parties: Buying property as legal owner (using a friend or family member to purchase property on their behalf)
- Manipulation of Property Values: Buying and selling property at prices above or below market value
- Large Deposits (avoiding reporting thresholds): Paying large deposits for property with checks from multiple banks
- Use of Tenants for Commingling Funds: Using a "tenant" collaborator to combine funds to cover rent payments
- Illicit Funds for Renovations: Using illicit funds to pay for unnecessary renovations and improvements
- Shell Companies/Trusts: Using shell companies, trusts, and company structures
- Overseas Investment: Foreign criminals investing in real estate
- Excessive Renovation: To distance from criminals from the property they own
Real Estate - Prime Target for Money Laundering
- Ease of Cash Purchases
- Disguising Ownership
- Investment Stability
- Increased Market Value
Sector Specific Fraud Tactics - Real Estate and Property Management
- Increase in Rental Application Fraud: Exploiting digital systems to forge documents, leading to higher eviction risk and bad debt.
- Rise in Title Fraud: Criminals altering property ownership records using stolen identities, securing fraudulent loans, or selling properties they don't own. Remote transactions risk this fraud.
- Luxury Real Estate as a High-Risk Target: Rental fraud is especially prevalent in the luxury market where fake documents often go undetected.
Gifts Declaration
- Submission: Gift requests through Concur before purchase.
- Value Limit: Gifts below US$100 are allowed; gifts exceeding US$100 need justification.
- Recipient Specification: Recipient company and individual names/amounts in gift request.
- Prohibited Acts: Offering gifts/hospitality for undue influence, during a tender/contract renewal, exceeding thresholds, using vouchers, etc.
Prevention Measures within Crane Capital Policies and Procedures
- Fraud Prevention: Information Technology Policy, Multifactor Authentication, Biometric authentication, Segregation of Duties, Invoice and Cash Management, and Whistleblower Protection
- Bribery & Corruption Prevention: Travel & Expense Policies, Gift Requests, Third Party Risk Management.
Notable Fraud, Bribery, Corruption, AML/CFT in 2024
- Evergrande: Accused of $78 billion fraud.
- MAS Imposes Composition Penalty: On Swiss-Asia Financial Services for AML/CFT breaches.
- TD Bank Fine: $3 billion fine over drug cartel money laundering.
- UK Engineering Firm Scam: Arup falls victim to a £20 million deepfake scam.
- Deepfake Musk Scam: AI-powered version of Elon Musk appears in thousands of inauthentic ads, creating billions in fraud.
Strengthening Cyber Resilience
- Zero-Trust Security Models
- Multi-Layered Encryption
- Biometric Security Systems
- Voice Recognition Technologies
- Generative AI Defenses
Principles of Data Protection (1/4)
- Data Protection: Embraces technologies/processes/workflows needed for the availability of data when needed.
- Data Security: Safeguards data against theft, corruption, or unauthorized access throughout the data lifecycle.
- Data Privacy: Understanding the collection, use, management, and monetization of sensitive data.
Principles of Data Protection (2/4)
- Data Minimization: Collect only necessary data.
- Principle of Least Privilege: Authorized users are granted the minimum access required for their work.
Principles of Data Protection (3/4)
- Data Classification and Encryption: Classifying data by sensitivity and importance (e.g., Personal, Work - Unprotected, Work - Protected, Confidential, Highly Confidential) and protecting it via encryption.
Principles of Data Protection (4/4)
- Password Vault: Store passwords centrally and protect them with encryption to eliminate the need to memorize multiple passwords.
- Data Storage and Backup: Secure methods for storing data and proper disposal of no-longer-needed data.
- Prevent unauthorized access: Preventing unauthorized access, breaches and data leaks.
Cybersecurity Hygiene (1/2)
- Common Cyber Hygiene Problems: Weak Passwords, Ignoring Updates, Clicking on Suspicious Links, Not Backing Up Data, Sharing Too Much Online.
Cybersecurity Hygiene (2/2)
- Prevention Measures: Regular Software Updates, Strong Password Policies, Phishing Awareness, Secure Wi-Fi Practices, System & Network Security, Regular patching, Secure third-party access, Monitoring for unusual activity.
Business Continuity
- Business Continuity Planning: Ensure Crane Capital can continue operating during and after a crisis.
- Disaster Recovery: Processes for restoring IT infrastructure, data access, IT resources after a disaster.
- Crisis Management: Focus on responding effectively to unexpected events.
Business Continuity - Recovery Strategy
- Recovery Strategy for Office premise compromise, IT equipment destruction, and other scenarios.
Crisis Management - Crisis Classifications and CMT
- Crisis Classification Levels: RED (imminent threat), ORANGE (moderate risk), and YELLOW (low risk) based on impact.
- Crisis Management Team (CMT): Key contact persons responsible for crisis response, including alternate members.
- CMT Responsibilities: Ensuring Crane Capital can operate during and after a crisis, planning for uninterrupted operations, coordinating crisis response, allocating resources, and monitoring communication protocols.
Crisis Communication
- Crisis Communication Plan: Focus on minimizing damage when responding to unexpected events.
- Crisis Communications Coordinator: Contact numbers available for different departments in Hong Kong and Singapore.
Incident Reporting
- Introduction: Crane Capital's formal process for managing incidents to protect its reputation and operations.
- Key Elements: Incident Types (e.g., fraud, theft, cyber threats), Response Strategy (e.g., notification to crisis management team, investigation, validation), and Incident reporting form /process (5W1H)
- Incident Notification: Report incidents to the CMT as soon as possible (ideally within 1-3 hours).
- Incident Investigation: CMT validates and determines whether further investigation is required.
- WSIB Reporting: Reporting escalated incidents to WSIB (if applicable).
- Incident Closing and Following-Up: Incident Resolution, Communication, Corrective action, Internal control verification and Incident closure.
Information Security Incidents
- Examples: Unauthorized disclosure of sensitive information, theft/loss of device, virus/malware outbreaks, denial of service, attempts to gain unauthorized access, compromised user accounts due to phishing.
- Contact Methods: ECI (External Cyber Incident) Security Operations Center (SOC) Contact - Primary Method (email - [email protected]) and SOC Hotline Numbers for different regions (US, UK, HK, SG).
Closing Remarks – Reminder on Ethics Standard
- Reduce Risk: Helps reduce the likelihood of misconduct, regulatory violations, legal actions and reputational harm.
- Promote Ethical Culture: Fosters a workplace culture that prioritizes integrity, honesty, and transparency.
- Employee Engagement: Engage employees who understand the importance of ethics and compliance.
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Description
Test your knowledge on third party risk management and due diligence procedures. This quiz covers red flags, escalation protocols, and the primary objectives of engaging third parties. Enhance your understanding of the Crane Capital Risk & Compliance Training and the risks associated with title fraud in real estate.