监管政策

反洗钱 (AML) 政策：分步指南（带模板）

Posted on by Aiying

为了防止洗钱 (ML)，政府采用防御性监管 AML 和 KYC 政策，所有金融企业都必须采用这些政策。因此，企业应该学习如何将这些复杂的规则转化为健全的反洗钱政策和程序。

什么是反洗钱政策？

反洗钱政策是阻止 犯罪分子将非法所得资金伪装成合法收入的综合措施。金融机构必须强制执行，并受到监管机构的监督。

反洗钱政策旨在制定公司系统和控制措施的总体结构，以打击洗钱（ML）和恐怖主义融资（TF）。应确定反洗钱风险偏好、容忍度、不可接受的客户类型、禁止行为、员工责任、员工权利、资格水平等。

反洗钱政策必须得到公司高级管理层的批准并定期审查。

反洗钱政策与反洗钱计划类似。这些术语可以互换，具体取决于司法管辖区。

 

为什么反洗钱政策很重要？

可靠的反洗钱政策非常重要，因为它规定了防止可疑客户和交易的措施和控制措施。如果在审计过程中发现机器学习，它还可以保护企业免受巨额监管罚款。

 

反洗钱政策如何防止洗钱？

反洗钱计划通过客户尽职调查、交易监控以及检测和报告可疑活动来防止洗钱。这包括洗钱和恐怖主义融资的上游犯罪。

由于犯罪分子不断改进他们的洗钱方法，因此制定能够处理新的、复杂的洗钱尝试的反洗钱政策至关重要。否则，企业将面临财务和声誉损失。

 

谁需要反洗钱政策？

金融组织（例如银行）和洗钱风险较高的组织（例如货币服务企业、律师事务所、赌场、税务顾问、外汇经纪商等）需要可靠的反洗钱政策。是否需要取决于司法管辖区和具体的反洗钱法规。

 

谁来监管这个过程？

在国际层面，有金融行动特别工作组（FATF），这是一个全球洗钱和恐怖主义融资监管机构。FATF 发布防止洗钱的全球标准，而当地的反洗钱法规通常以此为基础（例如欧盟的 4、5 和 6 AML 指令）。

在国家层面，监管机构因国家而异。在德国，是 BaFin；在加拿大，是FINTRAC；在新加坡，是 MAS，等等。

 

创建 AML 政策的步骤

凭借为金融机构制定反洗钱政策的经验，我们对需要什么以及什么最适合企业拥有第一手的视角。我们的分步指南基于美国银行保密法 (BSA)、欧盟第四号反洗钱指令 (AMLD4)和 FATF 建议。

 

第 1 步：起草反洗钱政策声明

该文件可能包括：

  • 洗钱和恐怖主义融资的定义
  • 政策必要性的原因
  • 对公司“适当了解客户”的承诺
  • 承诺定期审计以符合监管要求
  • 定义公司有关预防金融犯罪的文化和价值观
  • 对员工进行反洗钱培训的原因

 

第 2 步：任命洗钱报告官 (MLRO)

企业需要指定一名反洗钱报告员，负责监督反洗钱系统和控制方面的反洗钱法规的遵守情况、接收有关可疑活动的披露并决定是否应提交外部可疑活动报告 (SAR)。

MLRO 应在公司内拥有足够的资历（例如成为高级管理层的一部分或对高级管理层负责）。MLRO 应具备：

  • 高级管理层的积极支持
  • 充足的资源
  • 行动的独立性
  • 获取信息
  • 提交年度报告的义务

 

第 3 步：执行客户尽职调查 (CDD)

客户尽职调查包括收集和验证相关客户信息，以及识别和评估他们带来的犯罪风险。这个过程涉及：

  • 识别客户并验证其身份
  • 识别受益所有人并验证其身份
  • 评估和获取有关业务关系或交易的目的和预期性质的信息

受监管实体应在以下情况下实施 CDD 措施：

  • 他们开始新的业务关系
  • 他们偶尔会看到交易
  • 有洗钱嫌疑
  • 有不可靠的文档
  • 有持续的监督义务

公司必须对其客户关系进行持续监控并不时更新客户尽职调查信息。他们还应根据客户、交易或业务关系的类型，确定客户尽职调查措施的程度以及基于风险的方法的持续监控。因此，企业应确定特定客户是否需要简化尽职调查、客户尽职调查或加强尽职调查。

CDD 还涉及通过制裁名单和不利媒体检查客户的标准程序。因此，企业应尽快了解制裁制度的变化。这可以使用监控制裁制度更新的特殊自动化系统来完成。在建立业务关系或为客户开立账户之前，金融公司必须核实他们没有雇用被列为金融制裁立法目标的人员（例如美国特别指定国民名单 (SDN) 上列出的人员），并确认提供服务不存在任何法律障碍。

 

第 4 步：验证客户身份

身份检查是反洗钱合规政策的核心。因此，公司必须制定全面可靠的措施，以便在开设账户或注册服务时准确验证客户的身份。

以下是 AML 政策必须涵盖的有关客户身份检查的 6 个相关要点：

 

1说明必须收集的文件和个人数据
公司必须根据当地反洗钱监管要求和基于风险的方法，确定哪些数据足以检查个人、公司和高风险客户。

向客户说明需要哪些文件以及原因非常重要。公司还需要说明当客户故意拒绝信息请求或提交虚假姓名、地址等时，将如何处理。

2 说明如何验证信息
公司必须说明他们将用来验证客户身份的方式。这可以通过收集文档、生物识别、数字身份、数据库搜索或使用验证软件或手动执行的方式组合来实现。

3 注明检查时限和候补名单条款
公司应说明验证客户需要多长时间以及对涉及未经验证账户的交易的限制政策。

4 说明如果无法验证客户必须做什么
反洗钱政策必须详细说明在无法识别客户的情况下采取的措施，即限制开户、限制交易、阻止用户等。

此外，该公司将无法与高风险或受制裁的国家和行业建立业务关系。

5 政治公众人物 (PEP)
PEP是担任或担任过强大公共职务的个人，例如高级政治家或法官。由于其影响力，政治人物更有可能参与协助或教唆洗钱、敲诈勒索和金融欺诈。因此，与政治公众人物合作会给金融机构和其他实体带来一定的风险。

由于 PEP 没有通用的定义，大多数国家参考金融行动特别工作组提供的定义：

现任或前任高级政府官员
属于某个政党的杰出政治人物
为政府官员的利益而成立的政府商业企业的高管
政府官员的近亲
金融机构的知名合伙人。

6说明身份验证外包给第三方时的程序

 

第 5 步：向金融情报机构 (FIU) 报告

公司必须明确如何向金融情报机构报告以及执法部门的信息请求。

 

第6步：与金融机构共享数据

反洗钱政策必须描述一个安全且保密的流程，用于与其他金融实体共享积累的反洗钱数据，并且不允许数据泄露。目的是识别和防止其他地方的洗钱活动。

 

第 7 步：填写可疑活动报告

反洗钱政策应指定可疑活动报告(SAR)所需的信息以及相关截止日期。例如，BSA 规定在发出罚款之前有 30 天的时间提交报告。

该示例模板可以方便企业使用，但是，全面的反洗钱政策还需要添加更多内容。

 

第 8 步：员工意识和培训

反洗钱政策应确保员工了解如何应对洗钱活动。因此，工作人员应定期接受以下主题的培训：

  • 洗钱/恐怖主义融资的风险
  • 相关法律及其义务
  • 公司 MLRO 的职责
  • 他们的公司如何处理潜在的洗钱或恐怖主义融资交易或活动

 

第 9 步：保存记录

这是指为审计目的而跟踪所有反洗钱相关程序和文件所采取的措施。公司还应该提及这些文件将保存多长时间。例如，根据BSA和 AMLD4，该期限为 5 年。

 

第10步：定期审核

公司应建立独立的内部审计职能，以：

  • 检查和评估当前反洗钱政策的有效性
  • 提出与本政策相关的建议
  • 监督公司遵守这些建议的情况

 

模板

重要的是要考虑到反洗钱政策的内容及其特征可能会根据业务和司法管辖区的不同而有所不同，还应反映相关业务的规模和性质，以及客户和客户的复杂性和地理分布。服务基地。

 

Aiying

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