Azərbaycan Respublikası Mərkəzi Bankı Banklara Nəzarət Departamenti
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- Bu səhifədəki naviqasiya:
- Examples of GOOD Practice 2 Examples of POOR practice
Supervision Department - AML/CFT Training CIP - Correspondent Banking - Monitoring - Review periods driven by the risk rating of a particular relationship; with high risk relationships reviewed more frequently. - Obtaining an updated picture for the purpose of the account and expected activity. - Updating screening of respondents and connected individuals to identify individuals/entities with PEP connections or on relevant sanctions lists. - Involving senior management and AML staff in reviews of respondent relationships and consideration of whether to maintain or exit high- risk relationships. - Where appropriate, using intelligence reports to help decide whether to maintain or exit a relationship. - Carrying out ad-hoc reviews in light of material changes to the risk profile of a customer. - Copying periodic review forms year after year without challenge from senior management. - Failing to take account of any changes to key staff at respondent banks. - Carrying out annual reviews of respondent relationships but failing to consider money- laundering risk adequately. - Failing to assess new information gathered during ongoing monitoring of a relationship. - Failing to consider money laundering alerts generated since the last review. - Relying on parent banks to carry out monitoring of respondents without understanding what monitoring has been done or what the monitoring found. - Failing to take action when respondents do not provide satisfactory answers to reasonable questions regarding activity on their account. - Focusing too much on reputation or business issues when deciding whether to exit relationships with respondents which give rise to high money- laundering risk. Examples of GOOD Practice 2 Examples of POOR practice Supervision Department - AML/CFT Training CIP - Wire Transfers - Banks‘ core banking systems ensure that all static data (name, address, account number) held on the ordering customer are automatically inserted in the correct lines of the outgoing MT103 payment instruction and any matching MT202COV. - Where practical, intermediary and beneficiary banks delay processing payments until they receive complete and meaningful information on the ordering customer. - Intermediary and beneficiary banks have systems that generate an automatic investigation every time a MT103 appears to contain inadequate payer information. - Following processing, risk-based sampling for inward payments identifying inadequate payer information. - Search for phrases in payment messages such as ‗one of our clients‘ or ‗our valued customer‘ in all the main languages which may indicate a bank or customer trying to conceal their identity. - Reviewing all correspondent banks‘ use of the MT202 and MT202COV. - Introducing the MT202COV as an additional element of the CDD review process including whether the local regulator expects proper use of the new message type. - Always sending an MT103 and matching MT202COV wherever the sending bank has a correspondent relationship and is not in a position to ‗self clear‘ (eg. for Euro payments within a scheme of which the bank is a member). - Searching relevant fields in MT202 messages for the word ‗cover‘ to detect when the MT202COV is not being used as it should be. - Paying banks take insufficient steps to ensure that all outgoing MT103s contain sufficient beneficiary information to mitigate the risk of customer funds being incorrectly blocked, delayed or rejected. - Banks have no procedures in place to detect incoming payments containing meaningless or inadequate payer information, which could allow payments in breach of sanctions to slip through unnoticed. - Insufficient processes to identify payments with incomplete or meaningless payer information. - Continuing to use the MT202 for all bank-to-bank payments, even if the payment is cover for an underlying customer transaction. Examples of GOOD Practice 2 Examples of POOR practice Supervision Department - AML/CFT Training CIP - Wire Transfers - Establishing a specialist team to undertake risk- based sampling of incoming customer payments, with subsequent detailed analysis to identify banks initiating cross-border payments containing inadequate or meaningless payer information. - Actively engaging in dialogue with peers about the difficult issue of taking appropriate action against persistently offending banks. Examples of GOOD Practice 2 Examples of POOR practice Yüklə 1,1 Mb. Dostları ilə paylaş:
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