SPECIALIST IN FINANCIAL MONITORING Project for updating professional standard SPECIALIST IN FINANCIAL MONITORING Godina Elena Head of the Center for Assessment of Qualifications in the sphere of AML/CFT Ноябрь 2018

Current standard Professional Standard: Specialist in Financial Monitoring (in the sphere of countering the legalization of criminal proceeds and the financing of terrorism) Approved by Order of the Ministry of Labor and Social Protection of the Russian Federation of July 24, 2015 No. 512n Has 3 levels based on 3 qualifications criteria Basic level - b (higher education (bachelor degree) and work experience of at least six months

Implementing internal control rules for AML/CFT Steps to create a system: professional standard List of qualifications:: Specialist of AML/CFT’ s unit in an organization Financial Investigator for AML/ CFT Head of AML/CFT’s unit in organizations Implementing internal control rules for AML/CFT Nivel 6 Conducting financial investigations for AML/CFT in the organization Nivel 7 Organization of financial monitoring for AML/CFT in the organization Nivel 8

Need for updating All professional standards must be updated to comply with the RF policy in the areas of migration, education, accessibility of work for persons with disabilities, international cooperation, digital economy, etc. Qualifications based on Profstandard should cover the entire labor market, providing an opportunity for each specialist in the field to confirm their qualifications Evaluation tools are developed on the basis of qualifications and in the context of labor functions. 3 qualifications are based only on 3 sets of qualification criteria for the entire labor market.

Need for updating The minimum standard level is 6, i.e. the professional exam can be passed only by those specialists who have an undergraduate degree and at least six months of work experience. It: Deselects specialists with secondary education from the labor market in the field of AML / CFT Contradicts the requirement of the Central Bank, allowing secondary education for specialists of small enterprises Does not allow university leavers to be accepted for specialists of small enterprises Does not allow university leavers with undergraduate education level to pass the professional exam.

Need for updating 3 qualifications allow to take exam only by three different sets of assessment tools, i.e. questions and objectives of the exam for professionals will be the same regardless of industry or supervisory authority. It: Reduces the possible range of exam questions and tasks to a minimum Does not create a comprehensive assessment tool on the market, since does not take into account industry specifics Does not allow supervisors or business communities to modernize the system without affecting the interests of the entire labor market in the area of AML / CFT

Need for updating Job descriptions based on professional standard Qualification professional examination Training programs meeting professional standard Assessment means are formed for each qualification

Changes AML/CFT -> AML/CFT/FPWMD Education Requirements: Secondary Vocational Education Additional programs: advanced training programs and / or professional retraining programs in the field of AML/CFT/FPWMD that have passed the Professional Public Accreditation Addition by 5th level Addition by labor functions that form three clusters: credit, non-credit financial and non-financial qualifications Addition by labor functions for scientific work and interaction with government bodies Separation of functions for work execution from their organization

Minimum level introduction: A5 Qualification Generalized labor function Labor functions Internal control specialist for AML/CFT/FPWMD Internal control for AML/CFT/FPWMD Implementation of internal control rules in the organization for AML/ CFT/FPWMD Implementation of the risk management program (ML/CFT/FPWMD) in the organization A5 qualification level requires secondary vocational education and passage of an AML/CFT professional development program, which has been professionally publicly accredited (confirmation of compliance of the educational program with professional standard)

Separation by labor conditions: A5 Qualification Generalized labor function Labor functions Specialist of AML/CFT unit in: credit organization non-credit organization non-financial organization Implementation of internal control rules in the organization for AML/CFT/FPWMD Implementation of internal control rules in the organization for AML/ CFT/FPWMD Implementation of the risk management program (ML/CFT/FPWMD) in the organization Identification of operations (transactions) subject to control for the purposes of AML/CFT/ FPWMD in a credit/non-credit/non-financial organization Control of implementation in the organization units of the internal control rules for the purposes of AML/FT/FPWMD Conducting training of corporate employees for AML/CFT/FPWMD In accordance with the recommendations of the FATF (A1) and the provisions of the Central Bank, organizations are divided into financial (credit and non-credit) and non-financial entities. 10

Separation by labor conditions: A6 Qualification Generalized labor function Labor functions Specialist of AML/CFT unit in: credit organization non-credit organization non-financial organization Implementation of internal control rules in the organization for AML/CFT/FPWMD Development of internal control rules for AML/ CFT/FPWMD In a credit / non-credit / non-financial organization financial organizationFPWMD Development of programs and procedures for AML/CFT/FPWMD in the organization Organization of work on the implementation of internal control rules for the purposes of AML/ CFT/FPWMD in an organization Organization of work on identifying transactions (transactions) subject to AML/CFT/FPWMD control in an organization Preparation of proposals for the improvement of legislation in the field of AML/CFT/FPWMD In accordance with the recommendations of the FAFT (A1) and the provisions of the Central Bank, organizations are divided into financial (credit and non-credit) and non-financial entities. 11

Conducting Investigations: C7 Qualification Generalized labor function Labor functions Financial Monitoring Manager AML/SFT/FPWMD system management Development of a set of measures to reduce the risks of AML/FT/ FPWMD Cooperation with state authorities and supervisory organizations in the field of AML/CFT/FPWMD Research activities in the field of AML/CFT/ FPWMD 12

Management in the field of AML/SFT/FPWMD: D8 Qualification Generalized labor function Labor functions Financial Monitoring Manager AML/SFT/FPWMD system management Development of a set of measures to reduce the risks of AML/FT/ FPWMD Cooperation with state authorities and supervisory organizations in the field of AML/CFT/FPWMD Research activities in the field of AML/CFT/ FPWMD 13

Work on professional standard The UTU Laboratory website: https://цок-подфт.рф/profstandart The website of the Council on professional qualifications of the financial market: https://asprof.ru/ Suggestions for revision and amendment of the standard should be sent to: info@utu-lab.ru Contact person in charge: Godina Elena Vladimirovna Elena.godina@utu-edu.ru 8 495 252 0109 14