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AML Seminar to Accountants - JFIU 4 March 2010

AML Seminar to Accountants - JFIU 4 March 2010. Stewart McGlynn Chief Inspector of Police Joint Financial Intelligence Unit. STR Filing. Suggested format & content detailed in JFIU website Email Fax Post Verbal (urgency - follow-up by hardcopy). Concerns. Urgency Confidentiality

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AML Seminar to Accountants - JFIU 4 March 2010

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  1. AML Seminar to Accountants - JFIU4 March 2010 Stewart McGlynn Chief Inspector of Police Joint Financial Intelligence Unit

  2. STR Filing • Suggested format & content detailed in JFIU website • Email • Fax • Post • Verbal (urgency - follow-up by hardcopy)

  3. Concerns • Urgency • Confidentiality • Tipping Off • Crime Report Vs STR

  4. Feedback • Acknowledgement of Receipt • File Ref. • Contact Person Details • Consent / No Consent Letter • Arrest / Prosecutions / Convictions • STR Quarterly Analysis Report

  5. Case Example 1 US$10M pledge US$9.7M loan Mr. X, Chairman of Board of Directors for ABC Company XYZ company Sole Owner of XYZ company is Mr. X

  6. Learning Points • Effective CDD / KYC • Good quality STR, allowing JFIU to perform its function • Protection

  7. Case Example 2 – Good Auditing Practice Winding-up Audit Company X Fraud and False Accounting

  8. Learning Points • Reported knowledge of Crime Proceeds – Fraud • Crime report could have been made but STR acceptable in this case • Urgency? Unsure? Contact JFIU

  9. Case Example 3 – Good KYC / CDD Frequent substantial withdrawals from Bank account of Company X in Hong Kong KYC / CDD By Accountant for Company X Discovery Director of Company X wanted in Japan

  10. Learning Points • Common sense, proportionate approach to KYC and CDD • If it looks like a duck………. • No risk of prosecution

  11. Think About This • Poor / Negligible CDD / KYC • Absence of risk based approach • Sub Standard STR • JFIU unable to make assessment • What would you Think?

  12. Country Comparison STR filed by Accountants

  13. STR filed by Accountants

  14. Some Final Thoughts • JFIU understands the burden that CDD and KYC entails • Law / International Standards • Increase in quality STRs from the sector desirable – intelligence is our business • JFIU is here to help – Contact us

  15. Contact JFIU Telephone:2866 3366 Fax :2529 4013 Email:jfiu@police.gov.hk Mail:GPO Box 6555 Hong Kong stewartmcglynn@police.gov.hk Telephone:2860 3547

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