1. CAM COMPLIANCE TRAINING
Prepared by: Jean Similien/ Chief Compliance Officer
& Alexandra Allen/ Compliance Officer

2. OVERVIEW Bank Secrecy Act (BSA) Requirements: Customer Identification
Reports (FinCen CTR-112 & Fincen SAR-111)
Record Keeping (5 years)
Anti Money Laundering (AML) Law Requirements:
Know Your Customer (KYC)
Risk Assessment
Compliance Program

3. Money Laundering /CAM CAM ONLY CONDUCTS MONEY TRANSFERS CAM HQ AGENT
$$$
COMPLIANCE

4. Money Laundering Introduction to the Money Laundering:
The Bank Secrecy Act (BSA)
Anti Money Laundering Law (AML)
USA Patriot Act
Office of Foreign Asset Control (OFAC)
Financial Crimes Enforcement Network (FinCEN)
Know Your Customer (KYC)
Risk Based Approach (RBA)

5. Money Laundering /CAM Money Laundering
Money Laundering has become a priority for the United States Government since September 11, 2001 and to prevent such crimes, the Government has introduced new laws (Patriot Act) and special agencies.
CAM has therefore integrated into its body the Compliance Department in order to prevent Money Laundering activities. With the Collaboration of its Agents, the Compliance Department at CAM has developed a strong Compliance Program dedicated in recognizing and preventing the Money Laundering Activities in the Money Transfer Business.
How can you help detect Money Laundering and protect CAM and your business?
The following information will guide you in detecting
unusual and fraudulent activities. For any further details, you are
also required to read the Compliance Manual included
in the Compliance Package.
AGENT
CAM
AML

6. Vocabulary
Agent : An entity (business) that CAM authorizes the use of its license by written agreement to sell and receive Money Transfers.
BSA Act : Law established in order to criminalize the laundering of funds. Violations of this Act may result in severe criminal and civil penalties including fines and prison terms.
The USA Patriot Act : As a result of September 11,2001 this Act was enacted and amended the BSA in October 2001 to protect the United States against Terrorist Activities.
OFAC : “Office of Foreign Asset Control” which provides a list of Individuals or Foreign Countries that are involved in “International Narcotics Trades” and “Terrorist Activities” and with which the U.S. does not conduct business with.
FinCEN: Is The Financial Crimes Enforcement Network whose mission is to safeguard the financial system from the abuses of financial crime, including terrorist financing, money laundering, and other illicit activity.
This mission is achieved by:
Administering the Bank Secrecy Act;
Supporting law enforcement, intelligence, and regulatory agencies through sharing and analysis of financial intelligence;
Building global cooperation with their counterpart financial intelligence units;
Networking people, ideas, and information.

7. Vocabulary (Ctd.)
CTR : Form provided by the Government that can be used for criminal, tax or regulatory investigations. Company and any Agent involved in the transaction may be fined for not reporting transactions of $ 10,000 or more for the same individual within a one day period. (CTR Form FinCEN 104 attached)
SAR : Suspicious Activity Report, form provided by the Government to report transactions deemed to be suspicious. (SAR Form TD F attached)
Structuring : Term used to refer to individuals who transfer funds in various small amounts under the legal threshold of $3,000 in order to avoid providing identification.
Willful Blindness : Term used when an Agent or an Employee attempts or helps to violate the BSA (Helping the proceeds that derive from illegal transactions).
Valid Identification : An unexpired document expiration date is to be shown on the Identification. The Compliance manual lists the type of Identification accepted at CAM.

8. BSA / Anti Money Laundering
Everyone has to be aware of BSA requirements and apply them as required, particularly:
Monitoring Transactions over $3,000:
You must:
a) Verify the Sender’s Identity
b) Create and maintain a record of the Money Transfer regardless of the method of payment.
2) Retaining the records and documents for 5 years from the date of the transfers.
3) Reporting:
a) You must fill out a CTR for all transactions over $10,000
b) You must fill out a SAR for all suspicious activities

9. REMINDER REMEMBER TO FILE YOUR TRANSACTIONS
KEEP ALL RECORDS FOR 5 YEARS
Transactions of $3,000+ (including fees) must be filed in this order:
1) Copy of the Transfer Receipt (Air Bill)
2) Copy of the “Authorized Transaction Form”
3) Copy of a VALID PHOTO ID.

10. Description of CTR & Example
A Currency Transaction Report CTR / FinCen Form 112, is provided by FinCEN to facilitate the reporting of any transaction or multiple transactions of $10,000 in currency (Cash) or over within a period of one day by the same Sender to the appropriate authorities.
An example of CTR:
A client walks in your business at 10:00 AM and transfers $8,000 in cash to Haiti. Of course, you do your diligence by sending via fax a copy of the customer’s Valid Identification and by completing the “Authorized Transaction Form” provided to you by CAM.
Later that same day, the same customer walks in and transfers an additional 3,000 in cash from your business. You must comply by informing the Compliance Department of a transfer of $8,000 plus $3,000 from the same customer that same day. Remember, for transfers over $10,000 the Compliance Department will complete a CTR form that is required by the Government.

11. Description of SAR
The Suspicious Activity Report SAR (FinCen Form 111) must be filed electronically by the Compliance Department when reports of suspicion from the Offices or Agents are clearly indicated on the transaction’s patterns.
A suspicious transaction could be one of the following:
- Involves funds originated from illegal activities
- Is designed to evade intentionally the BSA requirements
- Appears to serve no business or other legal purpose.
The completed SAR reports are kept in files by the Compliance Department for five (5) years from the date of filing.

12. SAR Exemple
Three customers walk in to your business. You notice that they are together and they are either friends, family members or work together.
They make each a transfer of $3,500 totaling $10,500. This action should raise your suspicion and you should verify thoroughly their Valid identifications.
These customers may be using the method labeled “Structuring” as previously discussed in the Vocabulary section. These customers may be avoiding the filing of a CTR since each individual transfer was less than $10,000.

13. Know your Customer (KYC)
Overview
Knowing a customer implies the following:
Get the true identify;
Analyze the customer transactions history in order tp document its profile;
Be aware of the red flags.

14. Know Your Customer (KYC) (Definition)
Know your customer (KYC) is the due diligence and BSA regulation that financial institution must perform to identify their clients and ascertain relevant information pertinent business with them.

15. Know Your Customer (KYC) (Main Aspect)
Knowing a customer involves more than just having seen that person conduct transactions through your company. You must be able to match the customer to the transactions.

16. Know Your Customer (KYC) (Main Aspect, cont’d)
True identity: Due diligence (DD) files rely upon initial client screening. This definition requires validation of the customer’s identity – Knowing the client’s identity, not who they say they are. DD processes should use original Government picture ID.

17. Know Your Customer (KYC) (Main Aspect, cont’d)
One aspect of KYC checking is to verify that the customer is not on the Office of Foreign Assets Control’s Specially Designated Nationals list. This list contains thousands of entries and is updated at least monthly.

18. Red Flags
Customer provides doubtful Identification which you believe to be a fake one (such as same first and last name).
Customer attempts to make multiple transactions just under $3,000 in a short period of time (same day, 3 consecutive days, etc.)
Two / More Customers use similar IDs.
Customer uses false ID.
Customer refuses to provide his/her Valid Identification upon request.

19. Red Flags (Ctd.)
Customer’s address or name spelling or numeration types or picture does not match customer’s appearance (Age, Height, Sex).
An individual customer without a local address, who appears to reside locally because he/she is a repeat customer.
Customer walks in with various friends and each sends transfers to the same beneficiary.

20. Red Flags (Ctd.)
Customer sends many transfers just below amounts that require reporting or record keeping.
Customer changes transaction after learning that he/she must show ID.
Customer, trying to evade BSA requirements, uses 2 or more CAM locations or cashiers on the same day to break one transaction into smaller transaction.

21. KYC Example
A CAM Customer walks into your business 3 times a week with different amounts of less than $3,000. In a week, this customer transfers 6 transactions of $1,999 estimating an average of $12,000 a week. With that same pattern, imagine how much that same customer transfers in a month, in a year….. . In this case:
- Should we be aware about fraudulent activities?
- Could this customer be hiding his identity by not exceeding the $3,000 Identification Cap limit regulated by CAM?
- Could this customer be structuring by avoiding the $10,000 CTR requirements?
That is where the “KYC” comes into play. By using the “Know Your Customer” skills, you may obtain the customer’s picture ID and obtain additional information such as his or her occupation or activities.

22. GRAMM-LEACH-BLILEY ACT
CONFIDENTIALITY
GRAMM-LEACH-BLILEY ACT
THE SECURITY AND CONFIDENTIALITY OF OUR CUSTOMERS WILL NOT BE DISCLOSED EXCEPT AS PERMITTED BY LAW.
(PRIVACY PROVISIONS OF SUBTITLE A OF TITLE V OF THE GRAMM-LEACH-BLILEY ACT “GLBA”)
Form Privacy Act

23. AIR BILL REQUIRED INFO 4) ADDITIONAL INFO FOR $3,000 AND MORE:
CAM
9425 SW 72nd St
Miami, FL 33173
Ph. (305)
YOUR AGENT NAME
TEL. (888)
LICENSED BY: ……. DIVISION OF BANKS
LICENSE #
EXPEDITEUR / SENDER:
1) COMPLETE LEGAL CUSTOMER NAME
FIRST & LAST NAME
(NO TITLE SUCH: (MR., MME, REV, ETC)
2) COMPLETE CUSTOMER ADDRESS
NO. & STREET
CITY, STATE AND ZIP CODE
(NO P.O. BOX)
3) TEL. NO. (WITH AREA CODE)
BENEFICIAIRE / BENEFICIARY:
1) COMPLETE LEGAL BENEFICIARY NAME
FIRST & LAST NAME
(NO TITLE SUCH: MR., MME, REV, ETC)
2) COMPLETE BENEFICIARY ADDRESS
NO. & STREET (IF AVAILABLE)
CITY, STATE AND ZIP CODE (IF APPLICABLE)
3) TEL. NO. WITH AREA CODE
4) ADDITIONAL INFO FOR $3,000 AND MORE:
a) COPY OF FOTO ID
b) SOCIAL SECURITY NUMBER
c) OCCUPATION OR BUSINESS ACTIVITIES
d) SOURCE OF FUNDS (IF MORE THAN $10,000)

24. Exemple of Invalid Air Bill INFO
EXPEDITEUR / SENDER BENEFICIAIRE / RECEIVER
BOSS GREGER CAEIN MME PIERRE ABEL
1234 Main Street PICKUP
Miami, FL CAM
Phone: (305) Phone: ( )
BOSS BOSS ABEL ABEL
P.O. BOX BANQUE NATIONALE
Miami, FL COMPTE #
Phone: (305) Phone: ( )
GREGER CAEIN CAEIN
1234 Main Street Rue Toussaint
Miami, FL Port-au-Prince
Phone: (305) Phone: (453) 9876

25. Authorized Transaction Form
PART A – TRANSFERT INFORMATION:
Amount 2. Date 3. Third Party (Yes or No?)
PART B – SENDER INFORMATION:
First & Last Name 2. Address 3. Tel.
PART C – ID INFORMATION: (Clear Copy Yes or No?)
ID Type 2. ID Number 3. Third Party 4. Expiration Date
Country 6. Date of Birth 6. Sender’s Occupation or Business
PART D – ADDITIONAL INFORMATION:
Employed by 2. Employer’s Phone 3. Relationship
Use of Funds 5. Source of Funds
PART D – COMPANY INFORMATION:
1. Comments 2. Agency or Office Name 3. Verified by 4. Signature
IMPORTANT: By signing this form you certify that the sender appeared in person and the copy ID has been made from the original and you got a clear one to keep in your archive.

26. REMEMBER 1) Full Name, Address & Telephone Of Sender
THE FOLLOWING INFORMATION ARE REQUIRED FOR ALL TRANSACTIONS (OFAC)
1) Full Name, Address & Telephone Of Sender
(P. O. BOX NOT RECOMMENDED)
2) Full Name, Telephone, Address
& Bank Account Of Beneficiary (for Bank Deposit Transfer
3) For transactions over $3,000 the additional information below is required:
a) copy of the sender’s VALID IDENTIFICATION (Valid id = non-expired ID)
b) Sender’s Date of Birth, Social Security Number or Passport or Alien ID Number or Employer Identification Number
c) Sender’s Occupation
(Please do not provide vague or unclear occupations like worker or businessman etc…)
Please send via fax to the Compliance department a clear copy of the customer’s valid identification & Authorized Transaction Form

27. THE FOLLOWING ARE VALID ID (Valid id = non-expired & official ID)
VALID IDENTIFICATION
THE FOLLOWING ARE VALID ID (Valid id = non-expired & official ID)
Passport
Driver’s License
Resident Alien Card
Federal ID Card
Electoral Card
Certification of Naturalization

28. YOU MUST PROVIDE THE FOLLOWING FOR ALL TRANSACTIONS OF $3,000 AND OVER
REMINDER
YOU MUST PROVIDE THE FOLLOWING FOR ALL TRANSACTIONS OF $3,000 AND OVER
1) Photocopy of VALID IDENTIFICATION
2) SOCIAL SECURITY NUMBER
(DO NOT make a photocopy of the social security card)
AUTHORIZED TRANSACTION FORM
PLEASE FAX THE DOCUMENTS TO COMPLIANCE:
(305)

29. AGENT RESPONSIBILITIES
Agents must not provide their own address or telephone number on behalf of a customer conducting a transfer
Agents must obtain the current address and telephone number of the client
If you suspect a customer of providing a frivolous or unusual name you must request a valid photo ID to verify the client’s identification
If you are suspicious of a transaction you must contact the Compliance Department at the following number: (305) Ext - 144
Agent must retain the compliance records (customer’s ID, BSA training, Audit, etc,) for 5 years.

30. Investigation & Audit Federal Agency Investigation
Officers from Investigation Agency may conduct Investigation Visits;
All questions may be directed to the Compliance Department at CAM;
Letters received from any Institution in regards to Compliance and BSA requirements must be forwarded immediately to the Compliance Department.
IRS Officers may contact you for BSA Examination
Contact your Compliance Department Immediately
Refer the IRS Officer to the CAM Compliance Dept.
BSA Examinations are strictly conducted for the purpose of reviewing your BSA Knowledge & Procedures.

31. What is a Risk-Based Approach?
A process that allows reporting entities to:
Identify and measure potentially higher risks for money laundering and terrorist financing;
Develop strategies to mitigate those risks;
Focus resources in areas that are deemed to be higher risk.

32. Requirements
The compliance program must now include a documented risk assessment.
The risk assessment for money laundering and terrorist financing must take into account the following factors:
client and business relationships;
products and services, and delivery channels;
geographic location where activities are conducted; and
any other relevant factors.

33. Requirements (Cont’d)
The review of the compliance policies and procedures, including the risk assessment, risk mitigation and ongoing monitoring, must be done every two years.
The findings of the review, updates made to the policies and procedures relative to the review, and the status of their implementation must be reported in writing to the Compliance Committee.

34. CAM’s CONTACT 1) For Compliance Issues: Tel: (305) 598-0400 Ext-7144
Fax: (305)
2) For Customer Service Issues:
Tel: (305) Ext-7500 or 7562
Tel: (1-800)
Fax: (1-800) or
3) For Accounting Issues:
Tel: (1-800) Ext-7521
Fax: (1-800) / (1-866)