Course Description:

So your reporting entity implemented an AML/CTF program and everyone in the business committed to do what was needed. How much has changed in the intervening years since implementation and, more importantly, how do you monitor compliance with the program? Are you struggling with the roles set out in the three lines of defence? Whilst you may sit in line 2 are you dealing with the business and making decisions they should be making? Are you a part time compliance officer with a day job? What is your time allocation for the management of an AML/CTF program?

This program will work through the intricacies of managing all the moving parts of a program and looks at common issues found in AML/CTF programs.

Most programs were implemented in 2007 and, apart from changes around KYC, most programs have not moved down the maturity path. There has been, and continues to be, significant change. Has your program matured or is it still taking a minimalist approach? Have the board actually had any relevant training? When was the last time that you had an independent review? Was it actually independent? Does your risk assessment flow into your transaction monitoring?

Using real examples as case studies, this program is designed to help you understand:

  • The threat environment and areas of risk;
  • The importance of taking a holistic view;
  • The importance of your risk assessment in driving your control framework;
  • Where do the risks actually sit;
  • The importance of making compliance a KPI or hurdle to performance bonus achievement;
  • The importance of knowing who you are dealing with;
  • That the customers of your customer really are a concern;
  • Why the boards messaging gets lost somewhere in middle management;
  • What are you monitoring for and do your rules actually help you manage your risk;
  • Monitoring program compliance;
  • Managing outsource partners
  • Incident response

Seminar Fee Includes:

AM-PM Tea/Coffee
Seminar Material
Attendance Certificate
$100 Gift Cert for next seminar

Learning Objectives:

  • Understanding the importance of monitoring for compliance
  • Maturing your program
  • Monitoring compliance
  • Dealing with outsource partners who may be performing key functions on your behalf
  • Undertaking reviews

Areas Covered in the Seminar:

  • Current AML/CTF threat environment
  • Is your program up to date
  • Program Governance
  • Encouraging compliance
  • Examples of issues (case studies throughout the course)
  • Assessing the risk for your organisation and how that may change over time
  • Assessing transaction monitoring rule effectiveness and making a case for change
  • Assessing and monitoring contract performance and goods supplied post the contract award
  • Monitoring and testing for compliance

Who will Benefit:

  • Board Members
  • CRO's
  • MLRO's
  • AML/CTF teams
  • Financial Institutions
  • Banking Organizations / Investment Organizations
  • Insurance Companies
  • Foreign Exchange
  • Financial crime compliance managers
  • Internal auditors
  • Compliance staff
  • Fund Managers
  • Legal Officers
  • Bank Regulators
  • Financial Controllers
  • Regulatory Bodies / Regulators / Supervisors
  • Compliance Officers, Managements
  • Internal and External Auditors/ Intern Auditors
  • Independent Auditors
  • Staff with Roles and Responsibilities in AML Management and Oversight
  • Risk and Compliance Management
  • Consultants in the AML / CTF Industry
  • Compliance Analysts and Advisors
  • Company Management
  • Compliance Analysts
  • Operational Risk Managers

Course Outline:

Day 1 (8:30 AM – 4:30 PM) Day 2 (8:30 AM – 4:30 PM)
  • 8:30 – 9:00 AM: Registration
  • 9:00 AM: Session Start Time
  • Current regulatory environment
    • How does an AML/CTF issue or adverse compliance assessment report impact an organisation
    • Communicating the issues to the board and getting buy in
  • What makes an effective AML/CTF program
    • Knowing my obligations, knowing my customers, knowing my customers transactions and knowing my governance
    • Document, document and know where it all is
    • The importance of version control – what policy applied when
    • Reviewing your key documents and managing change
    • Driving the program to maturity
  • ML/TF risk assessments
    • Are your risk assessment outputs meaningful?
    • Do they transfer to your transaction monitoring?
    • Understanding the risk your customers’ customers may pose
    • Approval and oversight by the board and senior management
  • Appointing an AML/CTF compliance officer
    • What is the role and the responsibility?
    • Stability and consistency
  • Managing exemptions
  • Managing ongoing compliance
    • Who is doing what and when?
    • Multi-national programs
    • Business versus Group compliance monitoring
    • The three lines of defence
    • Operational compliance and / or regulatory compliance
  • Independent Reviews and their uses
    • Seeking value – ask for feedback
    • The importance of the work plan and the report
    • Inclusion of deeper dives
    • Common findings from Independent reviews
  • Transaction Monitoring
    • AML/CTF TM is a regulatory function
    • Are your rules effective?
    • Testing your monitoring
    • Does your monitoring comply with your program?
  • Q and A

Meet Your Instructor

David Harley CFE CAMS
Director at Delta Financial Crime Consulting Pty Ltd

EXPERT David Harley CFE CAMS – is a skilled and effective Anti-Fraud, Anti-Corruption and Anti-Money Laundering professional with over 30 years’ experience preventing, detecting and resolving issues that relate to fraud, corruption money laundering and terrorist financing. With a law enforcement background focused on criminal investigation and proceeds of crime, David has spent nearly 18 years working in a commercial environment dealing with fraud and corruption.

David has led the development of frameworks and policies, undertaken business partner reviews and lead a range of fraud and corruption investigations, across multiple jurisdictions, including Australia, Bangladesh, China, Indonesia, Papua New Guinea and the Pacific Islands.

He possesses an extensive repertoire of strategic and tactical knowledge and skills, including forensic technology, forensic accounting, data analysis and a range of investigation skills/methodologies, and is able to provide commercially and ethically sound remediation recommendations and systems-based solutions to mitigate future risks. David takes a holistic approach to risk and issue management and is committed to leaving a lasting and beneficial impact on businesses that extends long after the engagement is completed. An excellent communicator, teacher and mentor who regularly lectures in Certificate III in Investigative Services and Certificate IV in Government (Investigation) for registered training organisations.

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