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June 2007. AML Awareness Training. 2. Overview. This training session has been designed to provide you with information and guidance as to how to comply with your anti-money laundering (AML) responsibilities. It covers the following:What is money laundering? How does it affect Safaricom, its st
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1. Anti-Money Laundering Awareness Training
July 2007
2. June 2007 AML Awareness Training 2 Overview
This training session has been designed to provide you with information and guidance as to how to comply with your anti-money laundering (AML) responsibilities.
It covers the following:
What is money laundering?
How does it affect Safaricom, its staff and Agents?
What are the rules & penalties?
How do we fight it?
AML Awareness Test
3. June 2007 AML Awareness Training 3 What is money laundering? The Origin
The original meaning of money laundering was a method by which the proceeds of crime are converted into assets that appear to have a legitimate origin, so that they can be retained permanently or recycled to fund further crimes.
Money laundering got its name from a string of laundries that the Mafia used in the USA to front their illegal business.
4. June 2007 AML Awareness Training 4 What is money laundering? Modern day money laundering
The definition and scope of money laundering is a lot broader than the traditional ‘washing dirty money’ concept. It can be defined as:
Certain actions laid down in the Proceeds of Crime and Anti-Money Laundering Bill, October 2006
These include concealing, acquiring, using or possessing the proceeds of crime or making arrangements for another person to acquire, use or possess criminal proceeds.
For the purposes of money laundering, the proceeds of crime include property or economic benefits a person would gain, directly or indirectly, as a result of an offence committed in Kenya or anywhere else, irrespective of whether committed before commencement of the Bill.
So an offence of money laundering can be committed by a person merely having stolen goods in their possession.
5. June 2007 AML Awareness Training 5 What is money laundering? Common origins of illegal money:
Fraud
Extortion
Forgery
Theft
People Trafficking
Drugs
Smuggling
Tax Evasion
Terrorism
How big is it?
Although it’s almost impossible to say the exact amount laundered, it is estimated by the Revenue & Customs in the UK that the amount is...
UKŁ 25 BILLION a year
6. June 2007 AML Awareness Training 6 What is money laundering?
7. June 2007 AML Awareness Training 7 What is money laundering?
8. June 2007 AML Awareness Training 8 What is money laundering?
9. June 2007 AML Awareness Training 9 How does it affect Safaricom and you? All firms, whether offering financial services or not, should apply the principles of the regulatory obligations across the firm’s activities in the appropriate way.
The Safaricom Money Transfer product will be covered by Kenya money laundering legislation.
As a result you, as an Agent or Safaricom employee, have personal and legal responsibilities. This training session has been designed to provide you with information and guidance as to how to comply with these responsibilities.
10. June 2007 AML Awareness Training 10 What are the rules & penalties?
The legislation that affects you:
Proceeds of Crime & Anti-Money Laundering Bill 2006
The legislation covers ALL CRIME, no matter how small the financial gain.
11. June 2007 AML Awareness Training 11 What are the rules & penalties? Proceeds of Crime & Anti-Money
Laundering Bill 2006
The 3 principal offences above carry a penalty of 14 years imprisonment and/or Sh 5M fine for individuals and for corporates, a fine of Sh 25M or value of the property involved, whichever is higher.
12. June 2007 AML Awareness Training 12 What are the rules & penalties? Proceeds of Crime & Anti-Money Laundering Bill 2006
These 2 offences carry a penalty of 7 years imprisonment and/or a fine not exceeding Sh 2.5M or in case of corporates, a fine of Sh 10M or the value of the property, whichever is higher.
13. June 2007 AML Awareness Training 13 What are the rules & penalties? Summary:
You can be prosecuted for any of the five offences, or a combination of all five.
14. June 2007 AML Awareness Training 14 How do we fight it? Principal AML Controls
15. June 2007 AML Awareness Training 15 How do we fight it? Know Your Customer
16. June 2007 AML Awareness Training 16 How do we fight it? Reporting Suspicious Activity
17. June 2007 AML Awareness Training 17 How do we fight it? Red Flags – Typical examples of suspicious activity
18. June 2007 AML Awareness Training 18 How do we fight it?
19. June 2007 AML Awareness Training 19 How do we fight it? Suspicious Activity Reporting Form
Attached is the Suspicious Activity Report
20. June 2007 AML Awareness Training 20 How do we fight it? Who is the Money Laundering Reporting Officer (MLRO)?
The MLRO is the member of staff responsible for, among other things, the receipt, investigation and disclosure (where appropriate) of Suspicious Activity Reports to the Financial Reporting Centre.
The MLRO for Safaricom is Miriam Gikonyo.
The Fraud Manager for Safaricom is Edward Muchiri.
All Safaricom staff/Agents must use the Suspicious Activity Reporting (SAR) Form which will be sent to the
above staff in Fraud management via
M-pesafraud@safaricom.co.ke
What is the 4D technique mentioned on the SAR form?
The 4D technique will help you consider whether what you have seen may relate to criminal activity and is therefore suspicious or whether it is unusual but with a logical explanation. Unusual activity which is NOT suspicious should NOT be reported. The main headings of the 4D technique are as follows:
Details – What has happened? Do I need to know more?
Dates – When did it happen? Is it a one off transaction or a series of transactions?
Doubts – What made me suspect this relates to criminal activity? How well do I know the customer? Does anyone else know more?
Decision – You may decide; (i) That you are suspicious and therefore need to report the activity to the MLRO,
(ii) Not to report it as you have concluded that there is a logical explanation for the activity, or
(iii) Monitor the account to better understand the activity before making a final decision.
21. June 2007 AML Awareness Training 21 How do we fight it? What happens next to the report?
22. June 2007 AML Awareness Training 22 Summary In this course you have learnt
23. June 2007 AML Awareness Training 23 Knowledge Test
You will now be asked 10 questions on the subjects covered in this course.
You will be given your score at the end and will be required to re-take the test until you meet the pass mark of 70%.
Good luck!
24. Thank you.