SECTION A |
DAY 1 & DAY 2 |
I. AML: Past, Present and a New Future – Regulation Perspective |
1. History of Anti-money LaunderingLaws in the US |
- U.S. Key BSA/AMLRegulatory Developments Timeline
- U.S. Enforcement Developments
- International Developments
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2. AML Evolution in Vietnam |
- Legal Framework and Compliance Status Overview
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II. Compliance Culture & Risks of Non-compliance |
- Risks of non-compliance: Cases study
- Compliance culture and the Board of Directors’ roles in AML compliance
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III. Anti-money Laundering Act 2020 (AMLA 2020) |
- AMLA 2020
- Aim at Increasing BSA/AML Effectiveness and Modernization
- Increased BSA/AML Enforcement Tools and Authority
- Expanded BSA/AML Penalties
- Expanded Subpoenas Authority for Foreign Bank Records
- AMLA 2020 and Its Influence to the Development of AML/CTF Legislation Worldwide
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IV. FinCEN’s National Priorities: How Effective is Your AML/CTF Program |
- The first FinCEN’s 8 National Priorities and its Compliance Expectations.
- How “Effective” and “Reasonably Designed” your AML/CTF Program are?
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V. Money Laundering and Correspondent Banking |
- Money Laundering Risks posed by Respondent Banks and their Customers
- Practices for better understanding and managing the KYC and AML risks of respondent banking relationships.
- Technology systems and innovations that can strengthen correspondent banking risk governance.
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VI. Sanctions |
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1. Sanctions Origin and Legal Framework |
- Sanctions Origins
- Sanction Creation and Enforcement
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2. Sanctions Violations and Typical Sanction Evasion Schemes |
- Shell Companies
- Trade Finance
- Correspondent Banking
- Cryptocurrency (Venezuela “petro” digital currency, etc.)
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3. US Sanctions Update |
- Key updates on the US Sanctions
- Ukraine-/Russia- Related Sanctions
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4. Sanctions Compliance Program |
- Identifying and Managing Sanctions Risk
- Key Aspects of a Robust and Effective Sanctions Compliance Program
- Strategies for Strengthening Sanctions Compliance
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SECTION B |
DAY 3 |
I. AML Program Modernization |
- Current Challenges Across the AML Program
- The Need for AML Program Modernization
- Anatomy of A Modern AML Program
- Operation Considerations
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II. Enterprise-Wide Risk Assessment (EWRA) to Reflect New Threats/New Regulation Requirements and to Build a Modern Comprehensive AML/CTF Program |
- Inherent Risks Vs. Residual Risks
- Inherent Risks Considerations
- EWRA – Stakeholder Engagement, Stakeholder Accountability and Partnering for Success
- Risk Assessment Cycle
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III. AI, Machine Learning for AML Program Modernization |
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1. Challenges of Traditional AML Solutions |
- CompromiseCustomer Experience due to High False Positives
- Labor Intensive
- Inefficient due to Manual Involvements
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2. AML Tasks with Possible AI Application |
- Customer Identification and Verification (KYC)
- Transaction Monitoring
- Identification and Implementation of Regulatory Updates
- Automated Data Reporting
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3. Challenges for AI and Machine Learning as Part of AML Solutions |
- Data Quality
- Explainability of the Results
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SECTION C |
DAY 4 |
I. The Future of Transaction Monitoring |
- Challenges in Transaction Monitoring
- Regulatory Lanscape
- Use of Advancements in Technology
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II. Conducting or Supporting the Investigation Process |
1.Responding to Law Enforcement Investigation |
- Law Enforcement Investigations
- How to respond to Law Enforcement Investigation
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2.Conducting an internal investigation |
- Internal Investigation
- Necessary Steps in Conducting the Investigation
- Exploiting the Internet for Money Laundering Investigation
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3.Supporting the Investigation process |
- AML Cooperation Between Countries
- Mutual Legal Assistance Treaties
- Financial Intelligence Unit
- The Supervisory Channel
- FATF Recommendations on Cooperation Between Countries
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III. Synthesize and evaluate the AML/CTF program |
- Establish a robust AML/CTF Compliance Program
- An independent review of AML/CTF Program
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SECTION D |
DAY 5 |
Site visit and experience sharing from a US banks or money transmitter’s head office/agents. |
1. Introduction of the Bank’s AML program |
- A successful AML Program: accountability and commitment on behalf of Management/Board of Directors
- Challenges and obstacles in responding to changes and updates in laws and regulations
- Transaction monitoring and filtering system
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2. Case study |
- Real cases experienced by the Bank/Money Transmitter
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