Supervision Department - AML/CFT Training
Definitions GlosSTRy
2
Ponzi Scheme
A money laundering system named after Charles Ponzi, an Italian immigrant who spent 10 years in jail in
the U.S. for a scheme that defrauded 40,000 people out of $15,000,000. Ponzi‘s name became synonymous
with the use of new investors‘ money to pay off prior investors. Ponzi schemes involve fake, non-existent
investment schemes in which the investors are tricked into investing on the promise of unusually attractive
returns. The operator of the scheme can keep the operation going by paying off early investors with the
money from new investors until the scheme collapses under its own weight and/or the promoter vanishes
with the remaining money. The scheme recently engaged in by Bernie Madoff is an example of a Ponzi
scheme. The prime bank guaranty, roll program, bank debenture program and high yield promises are
frequently used to entice investors into participating in Ponzi schemes.
Predicate Crimes
―Specified unlawful activities‖ whose proceeds, if involved in the subject transaction, can give rise to
prosecution for money laundering. Most anti-money laundering laws contain a wide definition or listing of
such underlying crimes. Predicate crimes are sometimes defined as felonies or ―all offenses in the criminal
code.‖
Private Banking
A department in a financial institution that provides high-end services to wealthy individuals. Private
banking transactions tend to be marked with confidentiality, complex beneficial ownership arrangements,
offshore investment vehicles, tax shelters and credit extension services. Private banking is viewed by many
governments as highly vulnerable to money laundering.
Private Investment Company (PIC)
Also known as a Personal Investment Company, a PIC is a type of corporation that is often
established in an offshore jurisdiction with tight secrecy laws to protect the privacy of its owners.
In some jurisdictions, an international business company or exempt company is referred to as a
private investment company. PICs are viewed as prime money laundering vehicles.
Pyramid scheme
This is the same as a Ponzi scheme.
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Supervision Department - AML/CFT Training
Definitions GlosSTRy
2
Red Flag
A warning signal that should bring attention to a potentially suspicious situation, transaction or activity.
Regulatory Agency
A government entity responsible for supervising and overseeing a category of domestic institutions. The
agency generally has authority to issue regulations, to conduct examinations, to impose fines and penalties,
to curtail activities and, sometimes, to terminate charters of institutions under its jurisdiction. Most financial
regulatory agencies play a major role in preventing and detecting money laundering and other financial
crimes.
Remittance Services
Also referred to as giro houses or casas de cambio, remittance services are businesses that receive cash or
other funds that they transfer through the banking system to another account. The account is held by an
associated company in a foreign jurisdiction where the money is made available to the ultimate recipient.
Report on the Observance of Standards and Codes (ROSC)
A report used by the IMF and the World Bank that summarizes the extent to which countries observe
internationally recognized standards and codes for fiscal and monetary stability. The standards examine
monetary and financial policy transparency, fiscal transparency, banking supervision, securities, insurance,
payments systems, corporate governance, accounting, auditing and insolvency and creditor rights. Since
2002, they have also included examination of anti-money laundering and terrorist financing standards.
ROSCs summarizing countries‘ observance of these standards are prepared and published at the request of
the member country. The results are used in consideration of IMF and World Bank loans and for the private
sector (including rating agencies) for risk assessment. ROSCs are also useful in determining a country‘s
prospective risks associated with money laundering.
Reputation Risk
The potential that adverse publicity regarding a financial institution‘s business practices and associations,
whether accurate or not, will cause a loss of confidence in the integrity of the institution. Banks and other
financial institutions are especially vulnerable to reputation risk because they can become a vehicle for, or a
victim of, illegal activities perpetrated by customers. Such institutions may protect themselves through
Know Your Customer and Know Your Employee programs.
Respondent Bank
A bank for which another financial institution establishes, maintains, administers or manages a
correspondent account.
Supervision Department - AML/CFT Training
Definitions GlosSTRy
2
Retrospective Due Diligence
Examining the identity and activity of existing customers and their accounts to confinancial institution their
legitimacy. The Cayman Islands and the Bahamas, when adopting their anti-money laundering frameworks,
required financial institutions to perform due diligence on existing customers. The U.K. considered the
requirement, but did not implement it, citing the heavy burden on businesses in its financial sector. The U.S.
does not require retrospective due diligence.
Risk-Based Approach
The assessment of the varying risks associated with different types of businesses, clients, accounts and
transactions in order to maximize the effectiveness of an anti-money laundering program.
Risk Matrix
Document or chart that allows financial institutions to assess the money laundering risk of a business or
customer relationship. A risk matrix sets out critical elements or parameters of risk—such as the country of
origin or the type of anticipated transactions— so that institutions can calculate whether a potential client
presents a low, medium or high level of money laundering risk. Later, the matrix allows the institution to
make informed decisions on the frequency of transaction monitoring of particular accounts or customers.
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Safe Harbor
Legal protection for financial institutions, their directors, officers and employees from criminal and civil
liability for breach of
any restriction on disclosing information imposed by contract
or by any legislative, regulatory or administrative prohibition,
if they report their suspicions in good faith to the Financial Investigation Unit (FIU), even if they did not
know precisely what the underlying criminal activity was, and regardless of whether illegal activity actually
occurred.
Safe Deposit Box
A secure box inside the vault of a bank that can be used to store anything of importance a customer wishes
to protect, such as legal documents, jewelry, coins, wills, etc. Safe deposit boxes can also provide a useful
storage place for the proceeds of crime.
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