PLACEMENT
LAYERING
INTEGRATION
PLACEMENT
The first time funds derived from criminal activities are used in a legitimate
money transfer are referred to as Placement.
The physical disposal of cash proceeds derived from illegal activity. The first time funds derived
from criminal activities are used in a legitimate money transfer is referred to as Placement.
This stage poses the greatest risk to Money Services Business (MSBs):
Transactions may be structured to avoid recordkeeping or reporting
thresholds.
False identification and / or information may be provided.
LAYERING
Layering involves sending the money through various financial transactions to
change its form and make it difficult to follow.
Layering may consist of several bank-to-bank transfers, wire transfers between
different accounts in different names in different countries, making deposits and
withdrawals to continually vary the amount of money in the accounts, changing
the money's currency, and purchasing high-value items (boats, houses, cars,
diamonds) to change the form of the money.
This is the most complex step in any laundering scheme, and it's all about
making the original dirty money as hard to trace as possible.
INTEGRATION
At the integration stage, the money re-enters the mainstream economy in
legitimate-looking form - it appears to come from a legal transaction.
This may involve a final bank transfer into the account of a local business in
which the launderer is "investing" in exchange for a cut of the profits, the
sale of a yacht bought during the layering stage or the purchase of a $10
million screwdriver from a company owned by the launderer.
At this point, the criminal can use the money without getting caught. It's
very difficult to catch a launderer during the integration stage if there is no
documentation during the previous stages.
If the layering process has succeeded, integration schemes place the
laundered proceeds back into the economy in such a way that they reenter the financial system appearing to be normal business/legitimate
funds.
The return of funds to legitimate activities is referred to as Integration.
Anti-money laundering (AML) is a term mainly used in the financial and legal
industries to describe the legal controls that require financial institutions and
other regulated entities to prevent or report money laundering activities.
Anti Money Laundering processes and controls helps banks and financial
institutions to protect themselves and their reputation from the criminals.
Minimum Standards and Policies, approved by Senior Management, which clearly set
out your philosophy on crime prevention and business requirements.
Strong "Know Your Customer" checks at customer take-on to identify and exclude
known criminals but also to be sure you know the real identity of the customers you do
take on.
Robust training programmes for all staff.
Processes (very often automated) to monitor the activities on customer accounts to
identify suspicious activity and to check incoming and outgoing payments for
unauthorised transactions and to enable reports to be made to relevant authorities.
POLICY
Terrorism Financing
Tax Evasion
What is Terrorism?
What is FIU-IND
Financial Intelligence Unit - India (FIU-IND) is the central, national agency
responsiblefor receiving, processing, analyzing and dissemainating information
relating to suspect financial transactions to enforcement agencies and foreign
FIUs.
In their simplest forms, FIUs are agencies that receive reports of suspicious
transactions from financial institutions and other persons and entities, analyze them,
and disseminate the resulting intelligence to local law-enforcement agencies and
FIUs to combat money laundering.
As government agencies, FIUs must retain sufficient independence to accomplish
their objectives without undue interference or influence.
Functions of FIU-IND
The main function of FIU-IND is to receive cash/suspicious transaction reports,
analyse them and, as appropriate, disseminate valuable financial information to
intelligence/enforcement agencies and regulatory authorities.
The functions of FIU-IND are:
Collection of Information: Act as the central reception point for receiving Cash Transaction reports
(CTRs) and Suspicious Transaction Reports (STRs) from various reporting entities.
Analysis of Information: Analyze received information in order to uncover patterns of transactions
suggesting suspicion of money laundering and related crimes.
Sharing of Information: Share information with national intelligence/law enforcement agencies, national
regulatory authorities and foreign Financial Intelligence Units.
Act as Central Repository: Establish and maintain national data base on cash transactions and suspicious
transactions on the basis of reports received from reporting entities.
Coordination: Coordinate and strengthen collection and sharing of financial intelligence through an
effective national, regional and global network to combat money laundering and related crimes.
Research and Analysis: Monitor and identify strategic key areas on money laundering trends, typologies
and developments.
One receiver collects transactions from multiple senders on the same day
that total more than local Large Cash Transaction Reporting thresholds in
the Send/Receive country.
"U-turn" transactions, e.g. money passes from one person or company to
another, and then back to the original person or company
1.
2.
3.
4.
5.
6.
7.
As per RBI Guide lines one senior most official of the company must be
appointed as Principal Officer.
POLICY
Which are the circulars of RBI governing the applicability of PMLA for
Money Changing/Money Transfer business?
Typ
e
On the basis of the Due Diligence i.e KYC Norms stipulated by the RBI.
Customer Acceptance Policy.
Customer Identification Program.
Monitoring of Transactions.
Risk Management.
Risk
(i)
Regular customers who have been dealing with us for long time
Low
(ii)
Those
introduced
by
our existing
customers,
Sub-Agents,
Commission/Referral Agents, Travel Agents, general walk in customers
Medium
(iii)
High
KYC
AML&CTF Policy & Procedures is not intended for hindering the GROWTH
of the business.
It is not to make us defensive in our business approach
AML&CTF guidelines have been implemented to protect and prevent our
business from being misused for money laundering and terrorist
financing.
The policy of being too cautious is the greatest risk of all.
Please Contact:
R Ratnakumar| | Chief Compliance Officer - Anti-money Laundering (India)
UAE Exchange & Financial Services Ltd,
III Floor, Airlines Building, M.G. Road, Kochi - 682 011, India
Tel: 0091 484 3048179 | Fax: 0091 484 3048176|
Mob: 0091 9747196555
aoinspection@uaeexchange.co.in | www.uaeexchangeindia.com
Thank You..