About This Course
Structure
The course consists of a half-day, three-hour classroom session. The course includes significant hands-on learning with the practical analysis of real-world cases, proposed by the students themselves, which are then analyzed and discussed in plenary sessions or through exercises led by the instructor. Each half-day of training provides two training credits, necessary for renewing the certifications issued by the school (AMLACERT, KYCACERT, RCACERT, WSACERT) and the CAMS certification.
Program
INTRODUCTION TO THE OBLIGATION OF REPORTING
Reports of suspicious transactions:
legal nature and obligations of the recipients
– SOS: what they are and how they differ from other types of communication
– Objective communications and their relationship with SOS
– Relationships between due diligence obligations and reporting obligation with regard to to Politically Exposed Persons
THE “ANOMALIES” IN THE MATTER OF MONEY LAUNDERING AND FINANCING
TO TERRORISM: WHAT ARE THEY AND WHEN THEY OCCUR
– Introduction to anomaly indicators and to patterns of abnormal behavior.
– The provision of the Bank of Italy of 24 August 2010.
– The provision of 27 May 2009 in matter of proliferation of weapons of mass destruction.
– Instructions on data and information communications concerning suspicious transactions by part of the public administration offices (provision of 23 April 2018).
– Patterns and patterns of anomalous behavior
– UIF communication on anomalous use of virtual currencies.
METHODS OF REPORTING SUSPICIOUS TRANSACTION AND THE DEDICATED REFERENCE LEGISLATION
The procedure
– Preparatory phases for forwarding and managing the SOS (analysis, in-depth analysis, evaluation)
– Diversification of procedures depending on the subject
– Reporting methods for banking intermediaries and financial (regulations and GIANOS system)
– Reporting methods for professionals, with focus specific on chartered accountants and accounting experts (AS-SOS)
– Electronic transmission to the UIF and content of the report
Confidentiality requirements and sanctions
– Protection of privacy
– Operation of the communication ban
– Return flow of operations
– The sanctions
SOS IN OPERATIONAL PRESIDIARIES ANTI-MONEY LAUNDERING: WHAT HAPPENS AFTER SENDING TO THE UIF
UIF activities
– The RADAR system and financial analysis
Activities of the Guardia di Finanza, the DIA and the
National Anti-Mafia and Counter-Terrorism Directorate
– Relations between Authorities and division of responsibilities –
Memoranda of Understanding
– Investigative analysis and operational insight from part of the Guardia di Finanza
– A practical case study of reports of suspicious transactions
THE CONTRASTING FINANCING OF TERRORISM
Origins and purposes
– The birth of the CFT system and its relationship with the system anti-money laundering prevention
– The various definitions of terrorist financing in the Italian legal system
The Financial Security Committee
– Origin, composition and functions
Freezing of funds and economic resources – obligations of communication
Your Instructors
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