Anti Money Laundering Know Your Customer
Anti Money Laundering There is some very strong legislation in force in regard to Anti Money Laundering do’s and don’ts Much of it is good business policy and common sense
Anti Money Laundering Rules can get quite complicated and can sometimes be vague, unclear & open to (mis)interpretation Consider the goal though – to prevent fraud & other related crime, particularly Tax evasion
Anti Money Laundering These notes are not intended to train you in the arts of Anti Money Laundering, but merely to make you aware of the key points
Anti Money Laundering For more in depth information check solutions, videos, Team Zone, the internet
Anti Money Laundering - ID The basic idea is to make sure the person we are dealing with IS the person we are dealing with To this end we take ID and attach it to the contact record Tasks will be set up at key intervals to check we have the relevant records, but the most efficient way is to simply check when reviewing a client that we have ID This is called KYC – Know Your Client
Anti Money Laundering - Boookkeeping Other areas of potential issue is where clients have ‘suspicious’ transactions Larger than usual transactions Unusual transactions (like a payment to a known terrorist organisation) Sudden and /or dramatic changes to operations Most transaction types will be picked up when writing up or analysing accounts
Anti Money Laundering - Boookkeeping Alert AML issues immediately to SE via a task detailing why you think there may be an issue Be careful and not over zealous because viable AML concerns have to be reported to the authorities and can cause a lot of issues for the client if simply a result of bad bookkeeping or management
Anti Money Laundering - Script Hi John Its Bill from the accountants Tony asked me to give you a call to remind you that we still need some ID Could you let me have either A copy of your passport/driving license and a utility bill less than 3 months old thanks -Any problems, create a task for Tony
Anti Money Laundering - Notes Make notes of all conversations within notes on the Account or Contact Pages Alert via a Task to SE if you are asked to do anything that seems odd or illegal I cannot stress how important it is to log conversations whether by phone calls or meetings
Follow Up Tasks If relevant, e.g. client asks you to call again or you think a follow up is needed set a task for any follow up calls Or assign task to someone else
None Responsive Clients in General After a reasonable number of tries and the client is not responding, apart from going to visit the client, the only thing you can do is reassign the task and notes, detailing the problem to SE SE can then decide what to do Make sure that you the client from salesforce advising that you have called and why Also check you are contacting the right person (details are on the account)
Record Maintenance in General Updating records (especially Account & Contact records provide information so that you, the accountants, CRM and anyone involved in the job: Can have at their fingertips relevant information so they can do the job more accurately Automatic procedures can be set and fired We improve our own due diligence Opportunities for improved service, efficiency & income are created
Approaching Clients Remember when approaching clients – some people may not wish to discuss the issue with someone they don’t know At this point simply transfer to Tony or Stuart or advise the client that you will get Tony to Call – then update and assign the Task
Follow the compliance rules and keep us all out of trouble