Risk Management and Internal
Controls - KYC for Banks
Moderator John C. Bourbon
Chairman
United kingdom Compliance Institute
Risk Based Approach to AML/CFT
•Detailed Procedures
•Role of Money Laundering Reporting Officer
•Use of Technology driven solutions
What should a firm’s KYC
Framework look like?
•Guarding the door for new business
•Monitoring of existing clients
•Monitoring existing staff performance
•Robust recruitment Processes
What sort of Customer Due
Diligence procedures should be
established?
•Establish the full identity
•Obtain copies of Passport / Identity papers
•Check and verify full personal addresses
•Establish anticipated activity and model accordingly
What are the key controls ?
•Customer profiling
• Transaction profiling
•Sanctions screening
•Document retention
How should the key controls be
monitored?
•Defaults incorporated in reporting systems
•Reports produced for Compliance & MLRO
•Random visits by Compliance Officer and MLRO
•Internal Audit
•External Auditor
What are the key risk indicators?
•Unusual and unexplained transactions
•Large volumes with little economic logic
•Small transactions in bulking up into much larger single
transactions
•Transactions spread across a large number of outlets
What sort of training regime should be
put in place?
•All staff trained at least annually
•All staff tested annually
•Regular updates on latest trends and ideas
John C Bourbon MSc FCIB FCSI FCol
John Bourbon is licensed by the Isle of Man Financial Supervision Commission as a Trust and Corporate
Services Provider
Contacts:
www.complianceinstitute.co.uk
www.johnbourbonconsulting.com
E-mail johncb@manx.net
+44 7624 233603 / +44 7624 433603