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Glossary

AI Public Private Forum

The FCA and the Bank of England have launched 2020 a Public Private Forum to share insights into the use and impact of AI in financial services.

AML Compliance

Processes, policies and controls designed to ensure that companies comply with the requirements Anti-Money Laundering regulations and understand the AML relevant risks of conducting business.

AML Directives

The First AML directive was introduced on 10 June 1991, the second was introduced on 4 December 2001 and third was introduced on 26 October 2005. More or less it took 12 years to introduce the 4 th AMLD. The Fourth Anti-Money Laundering Directive came into force on 26 June 2017.
A year after the enactment of AMLD 4, the EU released the 5th AntiMoney Laundering Directive. Published on 19 June 2018, the directive should have been transposed into local legislation by 10 January 2020. AMLD 6 is upcoming.

API

‘Application Programming Interface’.

Essentially this allows different elements to communicate within one another. Think ‘tunnel’ for information.

Adverse Media

Adverse media or negative news  defined as any kind of unfavorable information found across a wide variety of news sources – both ‘traditional’ news outlets and those from unstructured sources. The risks associated with conducting business with persons or companies having an adverse media profile are many and varied.

Anti-Money Laundering

Also known as AML, this refers to processes, actions, laws and compliance regulations that are designed to make it harder for criminals to profit from crime.

Basel AML Index

The Basel AML Index is an independent annual ranking that assesses the risks of money laundering and terrorist financing worldwide. The Basel AML Index provides risk scores based on data from 17 publicly available sources, including the Financial Action Task Force (FATF), Transparency International, the World Bank, and the World Economic Forum.

CAMLMAC

The China Anti-Money Laundering Monitoring Analysis Centre established in 2006 is the central component of China’s Financial Intelligence Unit, which aims to prevent money laundering activities such as fraud, organized crime, terrorism, embezzlement and bribery, and financial fraud. The People’s Bank of China houses the Financial Intelligence Unit (FIU), which consists of CAMLMAC, Anti-Money Laundering Bureau (AMLB), and 36 PBC branches, each of which carries out aspects of the function of China’s FIU.

COSMIC

The COSMIC platform, which will focus on shell corporation abuse, illegal misuse of trade finance, and PF, was created by MAS and the six major Singapore banks, which are DBS, OCBC, UOB, SCB, Citibank, and HSBC. MAS plans to launch the COSMIC platform in the first half of 2023, and the platform will enable firms to securely share information about customers or transactions for which they have exceeded significant risk thresholds.

CRA

The Customer Risk Assessment is a risk-based assessment that must be performed on a customer and the proposed business relationship, transaction, or product by a financial institution or a designated non-financial business provider (DNFBP). The CRA results define the amount of client risk ratings, associated due diligence levels, and the frequency of reviews that must be undertaken.

Countering Terrorism Financing

Terrorist Financing is the provision of funds or providing of financial support to individual terrorists, terrorist groups and/or campaigns and non-state actors.

DNFBPs

DNFBP stands for “Designated Non-Financial Business and Professions“. The term is used by the FATF to identify non-financial sector businesses that constitute a money laundering and terrorism financing risk. The FATF defines DNFBPs as real estate agents, precious metals and precious stone dealers, lawyers, notaries, and other independent legal professionals, as well as accountants.

EAIB

The EU – AI Regulation provides for the establishment of the European Artificial Intelligence Board, to advise and assist the Commission in connection with the AI Regulation.
The EAIB facilitates effective cooperation between the national supervisory authorities and the Commission, coordinates and contributes to guidance by the Commission, and assists the national supervisory authorities and the Commission to ensure consistent application of the Regulation.

Enhanced Due Diligence (EDD)

Often mistaken as being ‘part of the KYC process’ Enhanced Due Diligence refers to the obligation to have a range of deeper, more stringent checks and controls designed to mitigate the risk in a particular customer relationship.

This can include stronger KYC measures but should also include stricter measures within transactions monitoring.

EuReCA

The EU’s central database for anti-money laundering and counter-terrorism financing. EuReCA will contain information on material weaknesses in individual financial institutions in the EU that competent authorities have identified.

FATF

The Financial Action Task Force is an Intergovernmental body established in 1989. The objectives of FATF are to set standards and promote effective implementation of legal, compliance regulations and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. There are currently 39 members of the FATF; 37 jurisdictions and 2 regional organisations (the Gulf Cooperation Council and the European Commission). There are also 31 international and regional organisations which are Associate Members or Observers of the FATF and participate in its work.

False-Positives

Cases that don’t warrant review, but which are flagged and as such must be reviewed.

Fawri Tick

Fawri Tick is a smart platform launched in September in the UAE that supports communication and coordination between relevant government authorities and facilitates the rapid detection of financial risks.

FinCen Files

The FinCEN Files are leaked documents from the Financial Crimes Enforcement Network (FinCEN) that have been investigated by the International Consortium of Investigative Journalists (ICIJ).

Financial Crime

Crime committed against a form of property, often involving the attempt to convert ownership to one’s own benefit.

GFIN

Global Financial Innovation Network.The network enables RegTechs to test their products and solutions across multiple jurisdictions at a time. Through the ‘global sandbox’ approach, the GFIN aims to identify potential areas of regulatory convergence that will make it simpler for businesses like RegTechs to develop and deliver global products and solutions.

GTO

GTO better know as Geographic Targeting Order is a US Reporting Requirement.

GoAML

The United Nations has launched GoAML as a software tool which is available to member countries designed to interface with international law enforcement entities like Interpol.

JMLIT

JMLIT (Joint Money Laundering Intelligence Taskforce)  is a partnership between law enforcement and the financial sector, established in the UK in 2014 to bring together banks, law enforcement, and regulators in both operational and strategic environments to collectively combat money laundering, terrorist financing, and related threats.

Know Your Business (KYB)

Another way of saying ‘KYC’ but referring specifically to the identification of businesses and legal persons. The major aim is to remove anonymity and identify structures that could be used to hide the ultimate beneficial owner.

Know Your Customer (KYC)

Also known as ‘KYC’, refers to the identification and verification of the identity of customers/clients. Regulatory requirements differ but the central aim is to remove anonymity from the financial system and deter criminal behaviour.

MENAFATF

The MENAFATF is voluntary and co-operative in nature and independent from any other international body or organisation; it was established by agreement between the governments of its members and is not based on an international treaty. It sets its own work, regulations, rules, and procedures and co-operates with other international bodies, notably the FATF, to achieve its objectives

Money Muling

A money mule is a person who transfers illegally obtained money between different payment accounts, very often in different countries, on behalf of others.
Money mules are also recruited by criminals to receive money into their bank account, in order to withdraw the money and in most cases wire it overseas, receiving a commission payment in return for the provided services.

NLG

Natural Language Generation (NLG) is a relatively new concept to the world of compliance. NLG enables compliance teams to automatically identify the most interesting and important information trapped in “structured” data and produce language that provides situational context, explanations, and potential actions.

NLP

NLP stands for Natural Language Processing. Companies are using natural language processing (NLP) (mostly) to unlock ” the value” of unstructured data.

Pandora Papers

Pandora Papers are leaked documents, disclosed following a joint investigation by The Guardian, BBC Panorama, The Washington Post and Le Monde. 12 million documents have been leaked.

Politically Exposed Persons (PEPs)

A person who holds an important public function. This can include heads of state, heads of government and senior politicians, but extends to a wide range of positions such as (in some jurisdictions) board members of publicly owned companies. Local requirements differ on the definition of a PEP and the extent to which this status applies to their family members and/or associates.

 

RegData

RegData is the Financial Conduct Authority’s new data collection platform for collecting regulatory data from firms. RegData makes it easier for companies to send their data by replacing the Gabriel system. All 52,000 companies that regularly provide regulatory submissions at Gabriel are now required to use RegData.

RegTech

From ‘Regulatory Technology’, referring to the use of technology to facilitate compliance regulations. The FCA was the first international body to promote the use of this term widely.

Regulations

Requirements created by regulatory and supervisory authorities. These are usually designated by lawmakers or governments to ensure stability or to protect the rights of consumers.

Regulators & Key Institutions

Financial regulators and Key Institution refers to the rules and laws firms operating in the financial industry, such as banks, credit unions, insurance companies, financial brokers and asset managers must follow.

SBML

Service-based money laundering schemes rely on exploiting the trade services or other intangibles to disguise and justify the movement of illicit proceeds.

Sanctions

Diplomatic measures used to try and defend the international law and protect natural security. These come in many forms and lead to restrictions on trade and economic activity, travel, cultural activity and diplomacy.

TBML

Trade-based money laundering is defined as the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimise their illicit origins.

TNML

TMNL is a Public-Private partnership of five banks in the Netherlands under the aegis of the Dutch Banking Association. With Transaction Monitoring Netherlands, these banks can collectively monitor payment transactions to look for signals that could indicate money laundering or terrorist financing.

The DFSA TIF

The DFSA TIF is the DFSA’s Cyber Thread Intelligence Platform is the first regular-led platform for information sharing within the DIFC done through a public-private partnership.

Transaction Monitoring

Transaction monitoring refers to the monitoring of customer transactions, including assessing historical/current customer information and interactions to provide a complete picture of customer activity. This can include transfers, deposits, and withdrawals.

Typologies

The term ‘typologies’ refers to the various techniques used to launder money or finance terrorism.

UBO

Ultimate Beneficial Owner (UBO) is a natural person who ultimately owns or controls an entity. This can be through multiple layers of complex ownership, or by a directly held percentage of the company. Where entities have no individual owner who ultimately controls 25% or more of the company, it is, in many jurisdictions now expected that the director(s) who control the business be listed as the beneficial owner.

UKFIU

The UK Financial Intelligence Unit resides independently within the National Economic Crime Command (NECC) as part of the NCA. UKFIU‘s primary mission is to receive, analyze and disseminate Suspicious Activity Reports (SARs).

UWO

Unexplained Wealth Order is a new legal tool in the form of a  court order issued by a British court to compel the target to reveal the sources of their unexplained wealth.
Persons who fail to account are liable to have assets seized after an enforcement authority, such as the National Crime Agency (NCA), makes a successful appeal to the High Court. The power of UWOs in fighting money laundering lies in their reverse onus principle.
As of October 2020, the NCA is the only body to have secured UWOs. The Serious Fraud OfficeHM Revenue & CustomsFinancial Conduct Authority and Crown Prosecution Service have authority but have so far not used the legislation

Wolfsberg Group

The Wolfsberg Group is a non-governmental association of thirteen global banks. Its goal has been to develop financial industry standards for anti-money laundering (AML), know your customer (KYC), and countering terrorist financing (CTF).

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