AML Requirements for Universal Bankers

Course Outline

Seat Time: 2.5hrs 

This course will introduce the learner to Anti-Money Laundering (AML) laws and regulations that the institution must adhere to. The course will define money laundering and will familiarize the learner with the various aspects of AML, including red flags, customer due diligence, and information-sharing policies. The course will also focus on how AML requirements pertain to the role of the Universal Banker at the financial institution. After completing this course, the learner will understand:

• How to identify the various red flags of money laundering.
• The role of OFAC and how an OFAC program should be implemented at the institution.
• The criteria that constitutes a high-risk person, product or service, and geographic location.

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 Entitities: This topic will introduce the learner to the types of high-risk persons and entities that s/he may encounter at the institution, such as corporate entities and cash intensive businesses, so that the learner is prepared to handle transactions with such customers.

T8. High-Risk Products and Services: The topic will define for the learner products which might be offered by the institution and the high-risk factors that accompany transactions with such products and services so that the learner can recognize the extra caution that must be taken.

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 visually recognize the different places in the United States where financial crimes and drug trafficking areas are located.

T10. Universal Bankers: Your Role in AML: This topic will familiarize the learner with the responsibilities of the Universal Banker in anti-money laundering and will provide the learner with a list of questions the staff should keep in mind.