A Practical Approach to the Fight Against Money Laundering and the Financing of Terrorism and Proliferation: the Establishment of an Internal Control System in the Non-banking Sector

To strengthen the knowledge of the subjects of the law about identification requirements, basic principles of research, verification and documentation methods of information provided by customers, basic operating principles and procedural procedures of the internal control system, as well as introducing the procedure for reporting suspicious transactions, which is a part of the internal control system.

• Outsourced accountants;
• Tax consultants;
• Sworn auditors and commercial companies of sworn auditors;
• Providers of services for the establishment and operation of a legal entity;
• Persons acting as agents or intermediaries in real estate transactions;
• Lottery and gambling organizers;
• Persons providing collection services;
• Legal or natural persons engaged in trade, if payments are made in cash: Debt recovery service providers;
• Virtual currency service providers;
• Employees who, in the performance of their direct work duties, are related to NILLTPFN issues.

• Perform customer identification, determine the true beneficiary and politically significant persons;
• Use techniques for checking, documenting and storing information provided by customers;
• Upon receiving the examples of the documents forming the internal control system, understand their characteristics and basic requirements for implementation in the organization;
• Will focus on the specifics of the submitted documents, analyze them, paying attention to details;
• Know the required minimum amount of documents and information, identifying a suspicious transaction and making an appropriate decision.

There are no specific prerequisites.

Training materials prepared by BDA.

Not intended.

Legal requirements for its subjects:

• Creating an internal control system;
• Duty of identification, investigation, verification;
• Monitoring, reporting suspicious transactions;
• Storage of documents.

Solutions for the implementation of the considered legal requirements:

• Creation of internal control system components (examples of procedures and registers);
• Forming a questionnaire and conclusion;
• Information verification channels (what, where to verify);
• Reporting obligation.