Financial crime prevention – Przeciwdziałanie przestępczości finansowej

• Introduction to the financial products market.
• Traditional financial products.
• Derivatives in financial markets.
• Innovative financial products (structured products, ETFs, cryptocurrencies).
• Introduction to the financial services market.
• Financial service providers (banks, neobanks, insurance companies, parabanks).
• Customers and financial services.
• Overview of financial services and how they are provided.
• Trends in the financial services market (e.g., blockchain).
• Supervisory institutions in the market for financial products and services.

Krystian Zawadzki

8h

• Ethics in the practice of finance.
• Standards of ethics in finance (based on the principles of the CFA Institute): professionalism, integrity in financial markets, obligations to clients and employers, standards for preparing analyses and recommendations, and conflicts of interest.
• Best practices and abuses: case studies.
• Ethical standards in the Polish financial sector.

Adam Marszk

4h

• Introduction to financial crime.
• Counteracting financial crime - global and local point of view.
• Regulatory landscape.
• The concept of operating models.
• Operational models for counteracting financial crime in the financial services industry.
• 3 lines of defence.
• Main roles and responsibilities.
• Main processes.

Artur Preus

12h

Key terms

• Understanding ML & its impact on global FI.
• 3 stages of ML.
• Methods of ML.

Risk assessment in AML

• Identifying & evaluating risks associated with ML in a financial context.
• New payment products & services (virtual currencies, crypto, prepaid cards, mobile payments, etc.).

AML Compliance Programs

• Elements of AML/CFT program in FI
• Development & introduction within FI

AML Investigation & Reporting

• Explanation of investigation process.
• Global cooperation in AML.

Technologies supporting AML processes.

• Role of Technology & Data Analytics.
• Overview of the tech tools supporting AML processes.
• Emerging technologies (blockchain, AI, ML) enhancing AML efforts.

The introduction to money laundering, including the history of money with interesting and practical examples.

• What is a financial crime?
• Historical context: why do we undertake measures to counteract money laundering and terrorist financing?
• The evolution of money; the current forms of payment.
• Money laundering - the concept & its stages (placement, layering, integration).
• Financial and non-financial institutions generating the risk of money laundering and terrorist financing (e.g., trusts, casinos, insurers).
• Presentation of most recent examples illustrating the negative impact and/or insufficient measures taken (or the lack of them) to counteract money laundering and terrorist financing (e.g., high-profile terrorist attacks).
• Case Study: How do you launder money in the best and most efficient way possible?
• Distinguishing ML and TF: Exploring the difference between money laundering and terrorist financing. Introducing the concept of “reverse” money laundering.
• Most recent cases (Sam Bankman-Fried, fin-influencers).

Kamil Orzoł

16h

• Focusing on identifying, assessing, and mitigating risks related to money laundering within financial systems and organizations.
• Understanding the risk exposure of the organization.
• Identifying high-risk areas, such as customer types, products, and geographic regions.
• Developing risk profiles for different scenarios. (PEPs, Hawalas, Pyramids etc.).
• Suspicious Activity Reporting (SAR): - Document and report suspicious transactions.
• Risk-Based Approach.
• Mitigation factors.

Alicja Zbronska

8h

Comprehensive framework of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income.

• AML/CFT - international regulations - FATF, Wolfsberg Group, Egmont Group, other international organizations.
• AML/CFT - EU regulations - AML Directives, including primarily the current regulations (IV,V Directives, Directive 2018/1673), Regulation on information accompanying money transfers and certain crypto-actives.
• AML/CFT - domestic regulations - : Anti-Money Laundering and Countering the Financing of Terrorism Act.
• AML Package - upcoming changes in the AML/CFT area - Single Rulebook Regulation, AMLA Regulation, 6th Directive.

12h

KYC Concept

• Introduction to KYC.
• Why KYC is needed?
• Client Due Diligence.
• What is CDD.
• Elements of CDD.
• How and how often to conduct CDD (e.g. periodic reviews).

Enhanced Due Diligence for high-risk customers

• What is EDD, why EDD is required?
• Customer relationships that require EDD.
• EDD measures.

Customer Identification and Verification

Short case study (given examples of different client types incl. high risk and asked which measures are required for which customer groups)

Risk factors in KYC

Identification and analysis of customer’s risk

ID & V of a customer

PEP customers

Sanctions

Alert lifecycle in the banking system

Case study: on the basis of presented event(s), analyse the event(s) and decide which CDD action should be applied.

The role of the Polish Financial Supervision Authority and similar institutions in the European banking system. Why do they exist? High-profile examples (e.g., Amber Gold)

The elements of practical CDD on the basis of a limited liability company / corporation; the analysis of publicly available information & documents (e.g., corporate structure, annual reports, UBOs, directors, screening, source of wealth, source of funds, sanctions).

Ownership structure; UBO; IBO.

Case study: analysing a selected company / corporation using public registers and publicly available information (e.g. ownership structure, directors, UBOs, sanctions, screening, annual reports).

What is risk-based approach in banking?

• The methodology of analysing customers subjected to risk-based approach; the level of risk (low / medium / high).
• Risk pyramid.
• Prohibited & restricted countries.
• Requirements for a customer depending on the risk level applied. Examples of natural persons/ companies & elements which increase the risk level.

Case study: using the examples provided and analysing the risk level that would be potentially applied to a customer.

Magdalena Ciszewska

32h

• Characteristics of Legal Forms: Understanding the impact of legal structures, such as limited liability companies or trusts, on money laundering (ML) and terrorist financing (TF) risks.
• Exploring Financial Corporate Information: Techniques for analysing financial statements and corporate documents to extract essential Know Your Customer (KYC) information.
• Ultimate Beneficial Owner (UBO) Concept: Navigating through intricate ownership structures to identify the UBOs.
• Sources of KYC Information: A practical guide on where and how to access reliable KYC data.
• Approaching Complex Entity Types: Strategies for dealing with investment funds and other multifaceted entities.
• Entity Risk Factors: Examining risks associated with bearer shares, nominees, shell companies, and state-owned entities.

Jan Westphal

8h

• Get to know your sources: introduction to most common types of online sources and online availability of the documents used for building a KYC Report.
• Identification of key registration and regulation information depending on corporate’s legal form and nature of business. Including: national corporate registries, financial and special business sector regulators, stock exchanges and reporting obligations set by the above.
• Identification and verification of people with significant control, directors and beneficial owners (both intermediate and ultimate).
• Initial assessment of customer risk and rising Red Flags (complex ownership, PEP, SOE, Shell Corp, Bearer Shares, Nominees, Correspondent Banking).
• Assessing credibility of secondary sources, definition of a golden source.
• Adverse Media Screening:
• 6AMLD Money Laundering 22 Predicate Offenses.
• Usage of keywords, search strings within Google search and World-Check One (LSEG product).
• Third-party AMS solution providers

Julia Lotkowska

8h

Presenting specific examples of red flags that we encounter in our daily work as AML specialists, when creating KYC profiles in personal banking (e.g. High Risk Third Countries, Gambling activities, Terrorist financing, Money transmitters, Scams, Vulnerability of specific products and services, Tax evasion). Presenting the appropriate risk base approach for KYC profiling. Paying attention to the assessment of risk factors. Investigation and assessment what should be treated as a red flag in the KYC profile and transactions monitoring. Then presenting specific examples of customer profiles that have experienced the above red flags. Analysis of what specific situations we should consider as risky and what we can mitigate. Actions required when an AML specialist detects red flags that pose a specific risk of financial crime.

HRTC
Gambling activities
Terrorist financing
Money transmitters and new payment methods
Retailers of high-value goods
Scams
Vulnerability of specific products and services
Tax evasion

Natalia Jacuniak-Strychalska
Agnieszka Dominguez-Gałąska

16h

Topics to be covered during the workshop:

Based on fictional onboarding requests for Individual and Corporate Clients, practice:
- performing initial risk assessment,
- identifying red flags,
- deciding on the next steps of the due diligence.

Using available external sources (e.g., company registries, stock exchange websites, "customer" websites), collect basic information on selected legal entities from various jurisdictions: legal name, previous names, date of incorporation/registration, company registration number, registration address, status, persons with effective control, customer base, nature of business etc.

Client Due Diligence for Individual Clients - discussing the challenges of remote ID document authentication. Based on real and AI-generated photos, discussing how to verify the authenticity of ID documents.

Discussing the main principles of an ownership structure analysis, understanding that the approach regarding ownership thresholds may differ from institution to institution. Based on fictional examples (various legal structures), practice analysing ownership structure:
- calculating aggregated %,
- identifying IBO and UBO.

Discussing name screening principles: evaluation of sources’ credibility, assessment of hits' materiality, methods of hits' mitigation. Based on real adverse media examples, practice assessing the negative news (sources, materiality, potential mitigating factors, potential impact on customer risk).

Discussing PEP screening process. Based on fictional PEP examples, practice applying EDD measures. Debating with the participants what additional DD measures should be taken to mitigate the heightened customer risk.

Practicing final risk classification based on fictional examples. The examples will include comprehensive customer profiles; the task for the participants would be to decide first, on retaining or offboarding the customer, and secondly, on a risk rating.

Martin David

8h

Essential aspects related to detecting and preventing suspicious financial activities.

• Introduction to Transaction Monitoring, the purpose and importance of TM.
• Understanding risk assessment and how it informs monitoring strategies.
• Various transaction types (e.g., wire transfers, cash deposits, electronic funds transfers).
• Red Flags and Suspicious Activity Indicators, recognising warning signs (e.g., unusual frequency, large amounts, structuring).
• Record Keeping and Documentation, record retention requirements.

Alicja Zbronska

8h

The workshops would be conducted by working together step-by-step with an experienced investigator, from the generation of the alert to formulating suspicions of a ML typology.

Topics to be covered:

• Review of the most typical scenarios involving cash transactions, money mules, rapid movements of funds, transit accounts, high risk geographies, etc.
• Most common scenarios for retail customers.
• Abuse of offshore shell structures for money laundering.
• Fictitious business transactions.
• Indicators of UBO concealment.
• Tax evasion schemes.
• Review of more complex scenarios. including corruption, misappropriation of corporate and public assets.
• Trade Based Money Laundering, etc.

Maciej Murdza

8h

• Definition of sanctions.
• Different divisions of sanctions.
• The objectives of sanctions.
• Historical background for imposing sanctions.
• Local and international sanctions regulations.
• Bodies imposing sanctions detailed description of UE, UN and USA.
• Forms of sanctions.
• FATF and its role.

Natalia Woźniak
Artur Chęcinski

8h

• Sanctions unveiled (Historical Context, Objectives, and Varied Types).
• Navigating Sanctions Evasion (Techniques Explored, Two Key Categories, Payment types).
• SDD-Sanctions Due Diligence (KYC-CSS vs SDD, Fortifying Privacy for Beneficial Owners).
• Sanctions Screening (Screening Targets – Customer name screening, Transactions/Payments screening, Trade activity screening, Capital markets screening, Influence of Technology, and consequential effects).
• Sanctions Investigation and Assets Blocking (Process Insights, Identifying/Blocking Payments, Decision Tree for Diverse Matches, Source Review).

Hayk Sakeyan

12h

• Legal and technological aspects of cryptoassets, particularly in light of MiCAR regulations.
• The ways in which the most common frauds in the financial market are used in crypto-assets and how to fight against them.
• International cases related to financial pyramids or other types of fraud using cryptoassets.

8h

• Advanced AML/CFT regulation of cryptocurrencies: A detailed consideration of global and local regulations, focused on understanding their impact on cryptocurrency operations.
• AML/CFT risk identification and analysis techniques for cryptocurrency transactions: a practical approach to using analytical tools to detect and monitor suspicious activity.
• Case studies: A set of real-world AML/CFT investigative scenarios that illustrate key strategies for identifying “red flags” and conducting effective analysis.
• Tools for monitoring and analysing blockchain transactions: An overview of the latest technologies to support AML/CFT investigative processes on the blockchain network.
• The AML/CFT Investigation process: A detailed discussion of the steps from identifying suspicion to analysing evidence to reporting and working with regulators.

Robert Pakla

8h

Excessive Compliance Costs
Effectiveness of AML & CFT Efforts
Compliance Checkbox Culture
Data Quality Challenges in AML & KYC
Managing False Positives in Screening
Defensive Suspicious Activity Reporting
The “Derisking” Approach and Its Consequences
Deepfakes and Fake News Challenges in Digital Customer Onboarding
Data Privacy vs. Transparency Dilemma
Transitioning from Rule-Based to Risk-Based Approaches
Perpetual KYC and Real-Time Monitoring

Jan Westphal

8h

A test covering knowledge of all materials of postgraduate study

Błażej Prusak

2h