What are the four pillars of LICU AML-CFT-CPF program
Appointing a dedicated Compliance Officer, developing comprehensive Internal Controls (policies, procedures), providing ongoing Employee Training, and conducting regular Independent Testing/Review of the program, ensuring all elements work together to prevent financial crime.
Would a member that operates as a real estate operator, and is reluctant to provide additional information raise money laundering concerns? Yes or No?
Yes
What should you do if you observe unusual client activity?
Bring to the attention of Compliance Department personnel.
What are the three member risk ratings at LICU
LOW, MEDIUM AND HIGH
What member types are considered high risk members at LICU
Non- residents; political exposes person; designated non-financial business and professions (DNFBPs) and OTHER major identified risks as directed by the Compliance Department
Are LICU staff allowed to share information with a member or prospect if the credit union decides to file a Suspicious Transaction Report ("STR")?
No, we are not allowed to share this information.
The most recent advisory from the FATF considers these two countries as high risk jurisdictions
Democratic People’s Republic of Korea (DPRK) and Iran.
January 1, 2009
What does the acronym CPF mean
counter proliferation financing
Who is in charge of submitting a suspicious transaction report?
The Compliance Officer
How would you generally define money laundering?
Money laundering is a process of turning dirty (criminal) money to clean (legitimate) money
What is the most important asset LICU can lose if we were a party to a member using us for money laundering purposes?
Reputational Risk – nothing can be damaged more easily than our reputation.
In Belize, how many years can an individual be sentenced to prison for money laundering activities? 2 years, 5 to max 10 years? - 20 years? - 30 years?
In Belize, an individual convicted of money laundering can be incarcerated for a term of not less than five years but which may extend to ten years, or receive a fine, or both.
When an individual deliberately ignores signs that an account is being used to launder money or engage in other suspicious activity it is considered what?
Willful Blindness