Money laundering prevention in the sale of banking and insurance products

Identification regulations for standard and special cases

• Special cases: Risk-based approach for non-standardized customer profiles.
• Simplified vs. enhanced due diligence obligations: When which procedures are required.
• Verification of identity documents and sources of information procurement.

Fit with PEPs (Politically Exposed Persons) and sanctioned countries

• Definition and detection of PEPs: risk increase and special testing requirements.
• Sanctions lists: Relevant lists and the obligation to review them.
• Dealing with high-risk countries: Risk mitigation and enhanced measures.

Dealing with complex structures and corporate clients

• Identifying the beneficial owners: challenges with complex ownership structures.
• Dealing with trusts, foundations and similar structures: Transparency requirements.
• Review of business registers and other data sources.
• Increased due diligence obligations for high-risk companies and complex customer structures.

Regulations on KYC (Know Your Customer) and source of funds verification

• KYC requirements: What needs to be documented and checked?
• Source of funds check: requirements and evidence to clarify the sources of funding.
• Updating customer profiles and continuous monitoring.
• Challenges in source verification: dealing with sources that are difficult to verify.

Business and transaction monitoring

• Risk-based monitoring of business transactions: Use of alerts and indicators.
• Automated vs. manual monitoring: advantages and limitations of the systems.
• Recognizing suspicious transactions: Typical patterns and indicators.
• Documentation obligations and reporting to the responsible authorities.

Updating documents

• Regulations for the regular review and updating of customer data; dealing with outdated or missing documents.
• Processes to ensure up-to-dateness: Measures for data quality assurance.

Dealing with anomalies

• Recognizing and acting on suspicious facts: From the internal reporting channel to the suspicious activity report.
• Examples of typical anomalies in sales.
• Training and sensitization of employees: Measures to increase awareness.
• Cooperation with the authorities: Procedure for reporting suspicions and legal requirements.