AML Requirements for Trust Investments

Course Outline

Seat Time: 2.5hrs 

This course will familiarize the learner with the crime of money laundering in particular to his/her position as a Trust Manager. This course will also provide a comprehensive overview of red flags and suspicious activity so that s/he may be able to recognize and report indicators. After completing this program, the learner will understand how to:

• Recognize the red flags of money laundering.
• Conduct Customer Due Diligence (CDD) practices and prevent money laundering at the organization.
• Recognize the roles that agencies such as OFAC play with regard to creating effective AML guidelines for the organization.

Course Topics

T1. Money Laundering: This topic will provide the learner with an introduction to the crime of money laundering, an act or attempt to disguise the source of money or assets derived from criminal activity, by providing the goals of money launderers and the steps of money laundering.

T2. Red Flags of Money Laundering: This topic will teach the learner about the warning signs that money laundering is occurring, such as avoiding reporting or recordkeeping or suspicious branch activities, so that the learner will be able to recognize red flags of money laundering.

T3. Customer Due Diligence (CDD): This topic will define customer due diligence procedures and will familiarize the learner with components of CDD and transaction monitoring programs.

T4. Information Sharing: This topic will help the learner understand what s/he is to do when the institution receives requests from other institutions, such as the federal law enforcement agency FinCEN, for financial information and will teach the learner about the requirements required of the institution if a match is discovered.

T5. Office of Foreign Assets Control (OFAC): This topic will discuss the purpose and use of the Office of Foreign Assets Control of the U.S. Department of the Treasury, and will explain compliance, restrictions, and certain types of transactions.

T6. OFAC Program: This topic will outline the development of an OFAC program for the institution, including internal controls that can be used to screen for suspicious activity or accounts. The topic will also address the reporting of suspicious activity.

T7. High Risk Persons and Entities: This topic will define high-risk persons and entities and will familiarize the learner with the various types of high-risk persons and entities that s/he may encounter at the institution, including non-resident aliens, politically exposed persons, non-bank financial institutions, and professional service providers.

T8. High Risk Products and Services: This topic will define high-risk products and services, including information on the use of physical cash in criminal activities and how to handle cash transactions, wire transfers, and more.

T9. High Risk Geographic Locations: This topic will teach the learner about the various domestic and international high-risk geographic locations that exist and includes detailed images that will help the learner recognize visually the different places in the United States where financial crimes and drug trafficking areas are located.

T10. TI: Your Role in AML: This topic will familiarize the learner with his/her role and responsibilities as a trust employee at the institution in regard to ensuring compliance with AML requirements.