Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
July 2007
Overview
This training session has been designed to provide you with information and guidance as to how to comply with your anti-money laundering (AML) responsibilities. It covers the following: 1. 2. 3. 4. 5. What is money laundering? How does it affect Safaricom, its staff and Agents? What are the rules & penalties? How do we fight it? AML Awareness Test
The original meaning of money laundering was a method by which the proceeds of crime are converted into assets that appear to have a legitimate origin, so that they can be retained permanently or recycled to fund further crimes. Money laundering got its name from a string of laundries that the Mafia used in the USA to front their illegal business.
So an offence of money laundering can be committed by a person merely having stolen goods in their possession.
Although its almost impossible to say the exact amount laundered, it is estimated by the Revenue & Customs in the UK that the amount is...
UK 25 BILLION a year
LAYERING
INTEGRATION
All three stages dont have to occur for money laundering to have happened. If you suspect activity in any stage, always report your suspicion to the Money Laundering Reporting Officer (MLRO) details of the MLRO are contained further on.
- May have involved an innocent customer. - Cost of fraud impacts the price of mobile services for legitimate customers. - Shareholders lose revenue.
Terrorist groups could be funded by criminal activities such as mobile phone related frauds
The legislation that affects you: Proceeds of Crime & Anti-Money Laundering Bill 2006
The legislation covers ALL CRIME, no matter how small the financial gain.
10
The 3 principal offences above carry a penalty of 14 years imprisonment and/or Sh 5M fine for individuals and for corporates, a fine of Sh 25M or value of the property involved, whichever is higher.
11
The 2 offences that Safaricom staff and agents ought to take note of are: Failure to Disclose An offence is committed if you know or suspect or have reasonable grounds for knowing or suspecting that someone is engaging in money laundering and you did not report it a soon as practical to the Money Laundering Reporting Officer (MLRO). Tipping Off A person commits an offence if they know that a disclosure has been made to the MLRO or the authorities, and makes a disclosure which is likely to prejudice any investigation. This includes dropping hints to the customer either intentionally or inadvertently and entering information onto front end customer service systems.
These 2 offences carry a penalty of 7 years imprisonment and/or a fine not exceeding Sh 2.5M or in case of corporates, a fine of Sh 10M or the value of the property, whichever is higher.
12
You can be prosecuted for any of the five offences, or a combination of all five.
13
14
By knowing your customer, you will be able to understand what is potentially suspicious.
Transactions that are not consistent with the known circumstances of the customer, should raise suspicions.
15
Money launderers often try to 'layer' funds by switching between several accounts in different institutions or jurisdictions in an attempt to throw the auditors off their trail. A legitimate customer, by contrast, will usually try to minimize bureaucracy and fees.
Unrealistic wealth compared with customer profiles Be wary of individuals with little or no apparent wealth, or no employment, who pay large sums of money into accounts. Often these funds are directly derived from crime, or are being 'looked after' while the real criminal is being investigated by police. Defensive stance to questioning Inexperienced launderers may not have prepared a reasonable cover story concerning the origins of their illicit funds. An 'honest' customer will, in general, be willing to answer questions about his finances because he wants the service provider to tailor its service to his needs.
Do not display or communicate any suspicion to the customer or a colleague if in doubt contact the Safaricom MLRO
Do not add any memos on the system stating that a report has been made and remember to destroy any hard copies of the report that may have been produced.
18
19
20
Advice the reporter if any action needs to be taken and whether or not the matter has been reported to the Reporting Centre..
Liaise with the Centre during their investigation.
Summary
In this course you have learnt
The definition and process of money laundering. How it affects Safaricom and you personally. The legal requirements and consequences. How to fight money laundering and terrorist financing as well as protect yourself and Safaricom.
Be alert at all times - follow these AML Guidelines or contact Safaricoms MLRO for advice
22 AML Awareness Training June 2007
Knowledge Test
You will now be asked 10 questions on the subjects covered in this course. You will be given your score at the end and will be required to re-take the test until you meet the pass mark of 70%.
Good luck!
23
Thank you.