Transcript AMLCFT_regime_June 9_Firms_2010

OVERVIEW OF
THE QFC / CFT AML REGIME
Date: 9 June 2010
By: Shaun Swan, Associate Director
Joy Smallwood (IMF resident advisor)
Christiane Chidiac, Manager AML/CFT
Qatar Financial Centre Regulatory Authority
1
AGENDA
•
Introduction and objectives
•
An overview of the AML / CFT Law (Joy Smallwood, IMF)
•
Key obligations under the AML/ CFT Rules for QFC Firms
•
Supervisory approach / regulatory expectations
•
Consultation feedback – revisions and updates
•
Working draft guidance discussion and questions
Qatar Financial Centre Regulatory Authority
Introduction and objectives
•
AML briefing sessions:
– have open and transparent communication with firms
operating in the QFC;
– brief firms on the requirements and obligations of the AML/CFT
Law and the AML/CFT Rules; and
– provide firms with clear information on our expectations when
implementing your obligations under the Law and the Rules.
Qatar Financial Centre Regulatory Authority
An overview of the AML / CFT Law
Joy K Smallwood
IMF Resident Advisor
June 2010
Qatar Financial Centre Regulatory Authority
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Overview of the AML/CFT Law
Background:
1.
Law passed to protect Qatar from money laundering (ML)
and the financing of terrorism (FT)
2.
2007 IMF AML/CFT Evaluation showed deficiencies in Qatar’s
previous AML/CFT legal framework
3.
New framework in line with Financial Action Task Force
(FATF) international standards
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
10 Sections
1.
2.
3.
4.
5.
Definitions
ML and FT Offences
Disclosure system at customs
National Anti-Money Laundering Committee (NAMLC)
Qatar Financial Information Unit (QFIU) and Suspicious
Transaction Reporting (STR) System
6. Preventive Measures
7. Supervisory Authorities
8. Investigative Procedures and Provisional Measures
9. International Cooperation
10. Sanctions
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Key Definitions include:
1.
2.
3.
4.
5.
6.
Proceeds of Crime - Any funds derived or obtained, directly
or indirectly, from one of the predicate crimes listed in
Article 2 (all felonies, international conventions, list of
proceeds generating crimes e.g. fraud, theft, smuggling )
Funds - Assets or properties of every kind
Money Laundering – see below
Financing of terrorism - see below
Financial Institution (FI)– 14 categories
Designated Non Financial Businesses & Professions (DNFBPs)
– real estate agents, jewelers, lawyers, accountants, trust
and company service providers
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Money Laundering: Defined as any of the following acts:
1)
2)
3)
The conversion or transfer of funds, by any person who knows,
should have known or suspects that such funds are the
proceeds of crime, for the purpose of concealing or disguising
the illicit origin of such funds or of assisting any person who is
involved in the commission of the predicate offence to evade
the legal consequences of his actions.
The concealment or disguise of the true nature, source,
location, disposition, movement or ownership of or rights with
respect to funds by any person who knows, should have known
or suspects that such funds are the proceeds of crime.
The possession, acquisition, or use of funds by any person who
knows, should have known or suspects that such funds are the
proceeds of crime.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Terrorism Financing : An act committed by any person who,
•
in any manner, directly or indirectly, and
•
willfully
•
provides or collects funds, or attempts to do so,
•
with the intention to use them or knowing that these funds will
be used in whole or in part
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for the execution of a terrorist act, or by a terrorist or terrorist
organization.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Money Laundering Offence – Article 2:
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Definition (above) plus
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Expanded list of predicate offences
- All felonies
- Crimes covered under int’l conventions to which Qatar is a
party
- A list of other specific proceeds generating offences
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Associated ML offences – including for FIs and DNFBPs
- Article 3
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Financing of Terrorism Offence – Article 4
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Definition (above) plus
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Offence considered committed irrespective of:
- any occurrence of a terrorist act,
- the place where it was committed or
- whether funds actually used to commit an act
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Filing Suspicious Transaction Reports (STRs) – Article 18:
Financial institutions, DNFBPs and non profit organizations to
promptly report suspicious transactions or attempted
transactions to the QFIU when:
- They suspect, or
- They have reasonable grounds to suspect
- Transactions could include funds that are proceeds of
crime, or
- Funds linked, related to or to be used for terrorist acts,
terrorist organisations or terrorist financiers
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Important protections when Filing STRs
- No Tipping off to customer/third parties permitted (art 39)
- Disclosure to competent authorities permitted
- Protection for liability for STR reporting in good faith
(art 82)
- Protection from breach of criminal, civil and breach of
professional secrecy provisions
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Customer Due Diligence (CDD) – Section 6:
- Identify and verify customer identities using reliable
independent source documents, date or information
- In a minimum of 5 situations:
1. when establishing business relationships,
2. during a domestic or international transfer of funds;
3. when doubts exist about the veracity or adequacy of
previously obtained customer identification
documents, data or information;
4. when there is a suspicion of money laundering or
terrorist financing;
5. when carrying out occasional transactions, with a
value equal to or above 55,000 Rials
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Financial institutions and DNFBPs have responsibility to:
1.
2.
3.
enquire about the anticipated purpose and the nature of the
business relationship and collect all relevant information.
identify the beneficial owner of the customer and take all
reasonable measures to verify his identity using reliable,
independent source documents, data or information such that
they are satisfied that they know who the beneficial owner is.
For legal persons and arrangements, these measures must
include taking reasonable additional measures to understand
and monitor the beneficial owner thereof as well as the
ownership and organizational structure thereof.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
If financial institutions, and DNFBPs cannot fulfill their
obligation of due diligence:
1.
2.
3.
they shall not establish or maintain the business relationship
Where appropriate, they shall make a report to the FIU in
accordance with this law.
Transitional provisions for 6 months (to October 31) for
implementation of CDD and correspondent banking provisions.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Financial Institutions and DNFBPs to put in place the following
measures:
1.
2.
3.
4.
5.
Exercise ongoing due diligence
Ensure CDD documents, data kept up to date
Take specific and adequate measures to address the risks of ML
and FT
Put in place risk management systems for PEPs
Keep records for 5 years, or longer if required by their
supervisor (6 years for QFC)
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
1.
2.
3.
4.
Financial institutions and DNFBPs to develop and implement
AML/CFT programs including the following internal policies,
procedures, systems and controls:
program management arrangements, and appropriate employee
screening procedures to ensure that they are appointed
pursuant to the highest standards.
ongoing training for officers and employees to assist them in
recognizing transactions and activities that may be linked to
money laundering and terrorist financing and instruct them in
the procedures to be followed in such cases.
audit arrangements to check compliance with and effectiveness
of the measures taken to apply the law.
compliance officer at department leadership level.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
For cross-border correspondent banking relationships, financial
institutions shall:
1.
2.
3.
4.
5.
6.
identify and verify the identification of respondent institutions.
collect information on the nature of the respondent institution’s
business.
evaluate the respondent institution’s reputation and the nature
of supervision to which it is subject.
obtain approval from senior management before establishing a
correspondent banking relationship.
assess the controls implemented by the respondent institution
re AML/CFT, and ensure that they are appropriate and effective.
Payable through account requirements –customer CDD,
monitoring and CDD information requests
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
For financial institutions who conduct domestic (including QFC)
and external wire transfer business (exceeding 4000 Rials, or
an equivalent value in other currencies), they must obtain and
verify the following information about the originators of the
transfers:
(1)
(2)
(3)
full name.
account number or, if there is no account number, a
unique reference number.
address, national identity number, customer identification
number, or date and place of birth.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
4. The information is to be included in the wire message or
payment form accompanying the transfer
5. Upon receipt of wire transfers that do not contain the
complete originator information, FIs should take measures to
obtain and verify the missing information from the ordering
institution or the beneficiary
6. Should they not obtain the missing information they shall
refuse acceptance of the transfer and report it to the Unit
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Supervisors have the authority to: (Article 42)
(1)
(2)
(3)
adopt the necessary measures to establish fit and proper
criteria for owning, controlling, or participating, in the
directorship, management or operation of financial institutions.
regulate and supervise financial institutions, NPOs and DNFBPs
for compliance with the obligations set out in this law, including
through on-site examinations, and the request of documents,
information, or records.
cooperate and share information with competent authorities,
and provide assistance in evidence collection, prosecutions or
proceedings relating to predicate offences, money laundering,
and terrorist financing.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
A supervisory authority may sanction its licensees (financial
institution, NPO, or DNFBP ) for a violation under the law, made
intentionally or by gross negligence, by imposing one of the
following measures and sanctions: (Article 44)
(1) ordering regular reports on the measures it is taking.
(2) order to comply with specific instructions.
(3) written warnings.
(4) replacing or restricting the powers of managers, board
members, or controlling owners, including the appointing of ad
hoc administrator.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
(5) barring individuals from employment within a business,
profession or activity , either permanently or for a provisional
period.
(6) imposing supervision, suspending license, restricting or
withdrawing any other form of permission and prohibiting the
continuation of a business, profession or activity.
(7) financial penalty in an amount no greater than 10 million
Rials.
(8) any other measures.
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Governor of the Central Bank (Article 48), without prejudice to
the authority of the Public Prosecutor,
- in cases where there is a concern about the disposal of
money laundering proceeds held at Financial Institutions
- or where there is suspicion that funds, balances or accounts
are being used in terrorist financing
- may order the freezing of the suspected funds, balances or
accounts for a period not exceeding ten business days,
- The public prosecutor shall be notified of such an order
within three business days of its issuance, otherwise it shall
be treated as void ab initio
- The public prosecutor may cancel the freezing order or
renew it for a period not exceeding three months
Qatar Financial Centre Regulatory Authority
Overview of the AML/CFT Law
Criminal Sanctions (Articles 72 - 76):
1.
2.
3.
4.
5.
Terrorist financing: 10 years in jail and up to a 2 million Rial
fine
Money Laundering: 7 years in jail and up to a 2 million Rial fine
Associated money laundering offences or tipping off: three
years in jail and a fine not exceeding 500,000 Rials
Failure to freeze terrorist assets by a financial institution or
DNFBP, a fine not exceeding 1,000,000 Rials
Breach of confidentiality by the FIU or by customs: three years
in jail and a fine not exceeding 500,000 Rials
Qatar Financial Centre Regulatory Authority
• Key obligations under the AML /
CFT Rules for QFC Firms
Qatar Financial Centre Regulatory Authority
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Key legislation and background to the new
AML/CFT Rules
Law No. 4 of 2010 on Anti- Money
Laundering and Combating the
Financing of Terrorism
QFC Regulatory Authority AML /
CFT Rules 2010
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Aligned to Law No. 4 of 2010 on Anti- Money Laundering
and Combating the Financing of Terrorism
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Ensure optimum compliance with FATF Recommendations
and standards
Qatar Financial Centre Regulatory Authority
Background to the new AML/CFT Rules
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close alignment with the FATF Recommendations and
standards through the use of key FATF terms and terminology;
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the rules set out a clear senior management responsibility for
AML/CFT responsibilities and the development of an AML/CFT
programme;
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more sophisticated risk-based approach to addressing firms AML/CFT
risks; and
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a single set of rules designed and structured to closely align
with how a firm would undertake the development and
implementation of an AML/CFT program and the ongoing
compliance with AML/CFT regulatory requirements.
Qatar Financial Centre Regulatory Authority
Key AML/CFT principles
The 6 key AML/CFT principles cover the following areas:
Principle
Principle
Principle
Principle
Principle
1
2
3
4
5
–
–
–
–
–
Principle 6 –
senior management responsibility;
risk-based approach;
know your customer;
effective reporting;
high standard screening and appropriate
training; and
evidence of compliance.
Qatar Financial Centre Regulatory Authority
Principle 1 - senior management responsibility
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Senior Management responsible for effectiveness of the firm’s policies,
procedures, systems and controls in preventing ML/TF (Rule 2.2.1)
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Senior Management must ensure that it:
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develops, establish and maintain effective AML/CFT policies, procedures, systems
and controls;
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has adequate screening standards;
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identifies, designs, delivers and maintains AML/CFT training programme;
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has an adequately resourced and independent audit function;
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has regular and timely information to Senior Management of ML/TF risks;
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has ML/TF risk management policies and methodology that are appropriately
documented;
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has in place an MLRO for the firm; and
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promotes an AML/CFT compliance culture
Qatar Financial Centre Regulatory Authority
Principle 1 - senior management responsibility
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Senior Management must ensure that there is at all times an MLRO for the
firm who:
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has sufficient seniority, experience and authority;
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has appropriate knowledge and understanding of their legal and
regulatory responsibilities under the AML/CFT framework;
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has sufficient resources to carry out the role;
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has timely and unrestricted access to all firm AML/CFT information,
including;
•
•
all customer ID documents
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all other documents, data and info for CDD and ongoing monitoring
purposes; and
•
all transaction records
appropriate back-up arrangements including a deputy MLRO
Qatar Financial Centre Regulatory Authority
Principle 2 – risk-based approach
•
Principle 2 (Rule 1.2.2) requires firms to adopt a risk-based
approach to the Rules
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Firms must
–
Conduct business risk assessment and decide risk mitigation
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Approach risk mitigation based on threat assessment methodology
–
Develop methodology by assessing the risk profiling and scoring of a business
relationship with a customer and must consider at least the following 4 risk
elements:
•
•
•
•
Customer risk
Product risk
Interface risk
Jurisdiction risk
Qatar Financial Centre Regulatory Authority
Principle 2 – risk-based approach
•
•
•
Customer risk
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Measures for PEP risks
•
Persons associated with Terrorism
Product risk
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Correspondent banking
•
Shell banks
•
Wire transfers
Interface risk
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Reliance on others
•
•
Introducers, Group introductions and Intermediaries
Jurisdiction risk
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ineffective AML/CFT regimes
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impaired international cooperation
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international sanctions
•
high propensity for corruption
Qatar Financial Centre Regulatory Authority
Principle 3– know your customer
•
Principle 3 (Rule 1.2.3) requires a firm to know each of its customers to
the extent appropriate for the customer’s risk profile
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Key Term – Customer Due Diligence Measures (Rule 4.2.1)
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Customer identification
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Verifying the customers ID, reliable, independent source documents,
data and information
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Establishing whether customer acting on behalf of another person
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Measures if customer acting on behalf of another person
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Measures if customer is a legal person or legal arrangement
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Establishing beneficial ownership
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Obtaining the source of customer’s wealth and funds
•
Obtaining information about the purpose and intended nature of the
business relationship
Qatar Financial Centre Regulatory Authority
Principle 3– know your customer
•
•
Part 4.3 of the Rules deals with CDD measures and ongoing measures
•
When CDD is required
•
Timing of CDD – establishing business relationships and one-off
transactions
•
Extent of CDD
•
Ongoing monitoring and procedures for monitoring
Part 4.4 and Part 4.5 of the Rules deals with enhanced and reduced /
simplified CDD measures
•
Sets out circumstances in which enhanced CDD must be performed
•
Sets out circumstances in which reduced / simplified CDD may be
performed
Qatar Financial Centre Regulatory Authority
Principle 3– know your customer
•
Part 4.6 of the Rules deals with 2 elements of Customer identification
documentation:
•
Customer
•
Nature of customer’s economic activity
Customer
•
Firms must make and keep records of all ID documentation it obtains
when conducting CDD measures and ongoing monitoring
•
Firms must make and keep records of how and when the steps of the
CDD measures were taken and completed
Customer’s economic activity
•
Firms must obtain and document information on the source of the
applicant’s wealth and funds
•
Firms must obtain and document information about the purpose and
intended nature of the of the business relationship
Qatar Financial Centre Regulatory Authority
Principle 4– effective reporting
•
Principle 4 (Rule 1.2.4) requires a firm to have effective measures in place
to ensure there is internal and external reporting whenever ML/TF is
known or suspected
Internal Reporting
•
Clear effective policies, procedures, systems and controls for internal reporting of all known or
suspected ML/TF instances
•
Direct access to MLRO
•
Obligation to report (STR) to MLRO (knows, suspects, grounds to know or suspect)
•
MLRO to document, acknowledge, consider, investigate, decide, notify reporter
External Reporting
•
Clear effective policies, procedures, systems and controls for reporting to the FIU of all known
or suspected ML/TF instances
•
Prompt reporting to FIU, consult with FIU before proceeding with transaction
•
Facts and circumstances of the knowledge or suspicion
•
Regulator notified in writing but NOT the STR
Qatar Financial Centre Regulatory Authority
Principle 4– effective reporting
•
Tipping off under Part 5.2 of the Rules
•
•
unauthorised act of disclosing information to the customer which
results in the customer knowing or suspecting the following:
•
that they are the subject of an STR ; or
•
that they are the subject of an investigation relating to ML/TF
unauthorised act of disclosing information that may prejudice action in
relation to offences, apprehension and prosecutions, recovery of
proceeds of crime and the prevention of ML/TF
•
Firms must ensure no tipping off occurs
•
Firms must ensure staff are aware of and sensitive to issues
surrounding and consequences of tipping off
Qatar Financial Centre Regulatory Authority
Principle 5– high standard screening and
appropriate training
•
Principle 5 (Rule 1.2.5) requires a firm to have adequate screening
procedures to ensure high standards when appointing or employing
officers and employees
•
Screening procedures focus on ‘higher-impact’ individual – role in preventing
ML/TF
•
Employment based on appropriate character, knowledge, skills and abilities to
act honestly, reasonably and independently
•
Procedures for higher-impact individual before employment must include
provision for:
•
Obtaining references
•
Employment history and qualifications
•
Regulatory actions
•
Criminal convictions
•
Accuracy and completeness of information
Qatar Financial Centre Regulatory Authority
Principle 5– high standard screening and
appropriate training
•
Principle 5 (Rule 1.2.5 (b)) requires a firm to have an appropriate ongoing
AML/CFT training programme for its officers and employees
Firms must
•
•
Identify, design, deliver and maintain an appropriate ongoing AML/CFT training
programme for staff, including:
•
Awareness and understanding of legal and regulatory responsibilities and
obligations
•
Role in preventing ML/TF
•
Liabilities incurred under the AML/CFT framework
•
Role of risk management, MLRO,
•
ML/TF techniques and trends and vulnerabilities
•
STR obligations
Training must be maintained and reviewed and improved if appropriate
Qatar Financial Centre Regulatory Authority
Principle 6– evidence of compliance
• Principle 6 (Rule 1.2.6) requires a firm to be able
to provide documentary evidence of its
compliance with the requirements of the AML/CFT
Law and the Rules.
Qatar Financial Centre Regulatory Authority
Supervisory approach / regulatory
expectations
Qatar Financial Centre Regulatory Authority
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“Dear CEO” letters
Compliance confirmation letters from Firms on or before September 15th
stating that the Firm has undertaken the following:






Review of Policies, Procedures, Systems and Controls
Development & implementation of the risk-based approach
Review customers files
Enhancement of AML/CFT compliance culture
Training to relevant staff
Independent Review of the AML framework
The letter should confirm whether or not the Firm is in compliance with the new
AML/CTF Rules 2010 of the QFC Regulatory Authority.
Areas of non-compliance + related remediation plan  to be shared with the
Regulatory Authority
Qatar Financial Centre Regulatory Authority
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AML/CFT Assessments
Risk Assessment & AML reviews will be conducted in light of the new AML/CTF
Rules – no interruption to normal assessment / review timetable.
AML Focused reviews – Supervisor reviews will focus, among other
items, on:
 The Risk-Based Approach
 Senior management buy-in / AML/CFT compliance culture
 Know Your Employees / Employees Screening
 Review of client files
 Reviews of policies, procedures, systems and controls particularly:
 KYC/CDD/Customer identification documentation
 Screening against sanction/suspect lists
 Transaction monitoring
 Suspicious Transaction Reporting
 Deputy MLRO arrangements
Qatar Financial Centre Regulatory Authority
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Firms not compliant with the new requirements
•
Firms will have until 15 September (after EID) to demonstrate full
compliance with the new AML/CFT Rules.
•
Firms not compliant with the new requirements of the 2010 Rules will be
dealt with by Risk Mitigation Programs (RMPs), letters… at this stage the
Regulatory Authority will educate Firms and assist them in complying with
the new requirements.
•
Non compliance with rules that also existed under the old AML Rulebook will
be dealt with via Breaches, RMP & enforcement action depending on the
gravity of the matter.
Qatar Financial Centre Regulatory Authority
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What do we expect firms to do?
ASAP, and in line with confirmation letter to send, we expect Firms to:
 Review of Policies, Procedures, Systems and Controls
 Develop:
- an AML business risk assessment
- an AML threat assessment methodology
- an AML Risk profiling and risk scoring of business relationships
methodology
 Review customers files
 Enhance the AML/CFT compliance culture
 Train relevant staff
 Undertake an Independent Review of the AML framework
Qatar Financial Centre Regulatory Authority
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What happens next?
•
Firms need to be able to demonstrate full compliance with the new AML/CTF
Rules
•
On or before Sept 15th, the Firm needs to file with the Regulatory Authority
the compliance confirmation letters stated previously
•
The AML team will be conducting reviews (onsite/offsite) to verify
compliance with the new AML/CTF Rules
•
The Regulatory Authority will be filing breaches and enforcing action in
relation to non-compliance with the new AML/ CTF rules
Qatar Financial Centre Regulatory Authority
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Consultation feedback revisions
and updates
Qatar Financial Centre Regulatory Authority
49
Feedback and revisions
•
CP submissions covered the following areas
•
Correspondent Banking – exceptions
•
•
Relaxation of payable through accounts provisions
•
•
Outcome – Rules clarified under 2.3.5 (3) that the Deputy MLRO is not required to be
ordinarily resident when acting as MLRO
Clarification sought on provisions relating to ‘Group Introductions’ (Rule 3.4.10) and the
extent of information to be provided by the introducer to the Firm
•
•
Outcome – no change as Rules in line with FATF recommendations
Clarification sought on the ordinarily resident requirement for the Deputy MLRO
•
•
Outcome – no change as Rules in line with FATF recommendations
Relaxation of ‘originator information’ requirements on wire transfers
•
•
Outcome – no change as Rules in line with FATF recommendations
Outcome – No change to the Rule – Information on obtained CDD needs to be provided
by the Introducer to the Firm, not the totality of the documentation collected.
Clarification sought on the status of the AML Regulations
•
Outcome – the AML Regulations have been superseded by the Law and the AML
Regulations are with the Minister for formal repeal
Qatar Financial Centre Regulatory Authority
Feedback and revisions
•
CP submissions covered the following areas
•
Clarification sought on the need to notify the Regulator when an STR is
submitted
Outcome – the Rules require Firms to notify the Regulator of an STR submission but does
not include the STR itself
•
•
Clarification sought on the extent to which screening requirements applied to all
prospective employees of a firm
Outcome – the Rules have been modified to focus on ‘higher-impact’ AML/CFT officers
and employees
•
•
Clarification sought on the extent to which screening requirements should be
applied across jurisdictions
Outcome – No change to the Rules, firms will need to satisfy themselves and be able to
demonstrate that they have taken appropriate measures in accordance with the rules
•
•
Reliance on others provision – Introducers (Rule 3.4.9 (3) (a)) requires firms to
receive an introducers certificate from the introducer
•
Outcome – Introducers Certificate – Approved Form Q20 on the website
Qatar Financial Centre Regulatory Authority
Working draft guidance
discussion and questions
Qatar Financial Centre Regulatory Authority
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