Compliance Best Practices - Citibank · Compliance Best Practices Tampa, Jun 2014 Gustavo Vidal...

Compliance Best Practices

Tampa, Jun 2014

Gustavo VidalFinancial Institutions LATAM, Miami ‐ USA

These materials are provided for educational and illustrative purposes only and not as a solicitation by Citi for any particular product or service. Furthermore, although the information contained herein is believed to be reliable, the following does not constitute legal advice and Citi makes no representation or warranty as to the accuracy or completeness of any information contained herein or otherwise provided by it.

Agenda

2

AML Context for FCB AML for FCB

Size of Money Laundering

3

$mm $bn $tn


4

$mm $bn $tn $qn

106 109 1012 1015

Fortune 100 – by 2012 Revenue (USD bn)

5Source: CNN Money: http://money.cnn.com/magazines/fortune/fortune500/2012/full_list/

447.0

127.2108.2

82.670.4 69.9 66.5

48.1 46.5 37.915.7 7.1

25.911.8 3.9

23.26.4 0.6 8.6 9.7

Wal‐M

art S

tores

Hewlett‐Packard

Apple

Procter &

Gam

ble

Home De

pot

Microsoft

PepsiCo

Amazon

.com

Coca‐Cola

Goo

gle

2 10 17 27 35 37 41 56 59 73

GDP (PPP) Latin America (USD bn)

6Source: The Wolrd Bank – DataBank – Economic Development Indicators

$1,904.2

$470.8

$373.3$300.9

$55.7 $42.5 $36.1 $31.4

Mexico Colombia Venezuela Peru Panama El Salvador Paraguay Honduras

2011 GDP (PPP) ($bn)

Large Numbers

7

Size of 1 Trillion

8Source: pagetutor.com

$100$10,000$1,000,000$100,000,000$1,000,000,000$1,000,000,000,000

1 Million – Seconds, Minutes, Hours

9Source: various

1 Million – Seconds, Minutes, Hours

10Source: various

Brazil World CupMay 25 2014Euro Cup

Jul 2012Einstein – 1st Scientific Work

1900

1 Billion – Seconds, Minutes, Hours

11Source: various

1 Billion – Seconds, Minutes, Hours

12Source: various

Spain World CupSep 1982

Right After Jesus85 AD

Homo Sapiens113K BCE

1 Trillion – Seconds, Minutes, Hours

13Source: various

1 Trillion – Seconds, Minutes, Hours

14Source: various

Paleolithic – Homo Sapiens30k BCE

Pleistocene – Homo Erectus1.9MM BCE

Cretaceus115MM BCE


15

12.318.1

25.532.2

42.5

57.2

83.1

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

0.30.5

0.70.9

1.1

1.5

2.12.2

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

World ML (US$ Tn)

FATF: 19892.0% = $0.4 Tn

CA = $67.4MM (6x)

IMF: 19983.5% = $1.2 Tn

CA = $114.6MM (10x)

UNODC: 20112.7% = $1.9 Tn$253.7MM (7x)

Source: The Wolrd Bank – DataBank – Economic Development Indicators | UNODC – Estimating Illicit Flows Research Report ‐ 2011

Fortune 100 – by 2012 Revenue / Profit (USD bn)


447.0

127.2108.2

82.6 70.4 69.9 66.548.1 46.5 37.9

15.7 7.125.9

11.8 3.923.2

6.4 0.6 8.6 9.7

Wal‐M

art S

tores

Hewlett‐Packard

Apple

Procter &

Gam

ble

Home De

pot

Microsoft

PepsiCo

Amazon

.com

Coca‐Cola

Goo

gle

1 2 3 4 5 6 7 8 9 10

Fortune 100 – by 2012 Revenue / Profit (USD bn)


2,200.0

447.0

127.2 108.2 82.6 70.4 69.9 66.5 48.1 46.5 37.915.7 7.1 25.9 11.8 3.9 23.2 6.4 0.6 8.6 9.7

AML Size

Wal‐M

art S

tores

Hewlett‐Packard

Apple

Procter &

Gam

ble

Home De

pot

Microsoft

PepsiCo

Amazon

.com

Coca‐Cola

Goo

gle

0 2 10 17 27 35 37 41 56 59 73

Fortune 100 – by 2012 Profit (USD bn)


2,200.0

505.6

AML Size Total Profits F‐100

23%



$1,904.2

$470.8

$373.3$300.9

$55.7 $42.5 $36.1 $31.4

Mexico Colombia Venezuela Peru Panama El Salvador Paraguay Honduras




$2,200.0

$1,904.2

$470.8

$373.3$300.9

$55.7 $42.5 $36.1 $31.4

AML Size Mexico Colombia Venezuela Peru Panama El Salvador Paraguay Honduras



21

15%

Source: The Wolrd Bank – DataBank – Economic Development Indicators

$2,200.0

$3,214.9

AML Size Countries


68%

Attractiveness to Money Launderers ‐ Rank Order

22

686634 617 600

497 476 466 449 439 429

Luxembourg United States Switzerland CaymanIslands

Austria Netherlands Liechtenstein Vatican City UnitedKingdom

Singapore

ML Attractiveness Index

Source: John Walker Crime Trends Analysis ‐Modeling Global Money Laundering Flows

Top 20 Origins of Laundered Money – Rank Order

23Source: John Walker Crime Trends Analysis ‐Modeling Global Money Laundering Flows

46%

5% 5% 5% 4% 4% 4%3% 2% 2% 2%

1% 1% 1% 1% 1% 1% 1% 1% 1%

Top 20 Flows of Laundered Money – Rank Order


19%

5% 4% 3% 3% 3% 2% 2% 2% 2% 2% 2% 1% 1% 1% 1% 1% 1% 1% 1%

Top 20 Destinations of Laundered Money – Rank Order


19%

5%4%

4% 3% 3% 3% 3% 3% 2% 2% 2% 2% 2% 2% 2% 2% 2% 2% 1%

Session Overview

26

AML for FCBAML Context for FCB

The Cost of Non‐Compliance is High

27

$199 Bn

69%

Source: The Banker – March 2014

The Cost of Non‐Compliance is High

28

Number of BSA/AML Enforcement Actions Continues to GrowAugust 2012 Turkish Bank Ltd. UK FSA. Fined 294,00 pounds for inadequate policies to manage its relationships with other banks, weak due

diligence on those banks and failure to keep proper records.

July 2012 HSBC testifies at the Senate Permanent Subcommittee on Investigation hearing on its AML shortcomings.

February 2011 Zions First National Bank. Concurrent OCC and FinCEN orders. Assessment $8mm. Focused on former foreign correspondent bank business.

October 2010 HSBC. FRB and OCC Cease and Desist order. Focused on firm-wide compliance risk management program, violation of Bank Secrecy Act and its underlying regulations.

May 2010 ABN AMRO (now the Royal Bank of Scotland). US Department of Justice. Forfeiture of $500M. Violation of the Bank Secrecy Act and violation of two laws underlying OFAC.

March 2010 Wachovia. $110M Forfeiture with DOJ, a civil money penalty of $50M and a Cease and Desist with OCC; civil money penalty of $110 with FinCEN. Alleged failures in the AML/BSA program.

January 2008 Sigue Corporation and Sigue, LLC. $12M Civil Money Penalty by FinCEN. Failure to implement effective controls to ensure compliance with BSA.

ING to pay $619 million over Cuba, Iran sanctionsNEW YORK | Tue Jun 12, 2012 4:10pm EDT

Lastupdated:August17,20101:25am

Barclaysfined$298moverSanctionsbreachBarclayshasagreedtopay$298m(£190m)toUSauthoritiestosettleinvestigationsrelatingtopaymentsthatthebankfacilitatedtocountriesfacinggovernmentsanctions.

August14,2012

StandardCharteredagreedtopaythestateofNewYorka$340millionfine. Thestatesaidthebankallegedlyconducted60,000transactionsforIranthatlefttheU.S.vulnerabletoterroristsanddrugkingpins.

HSBC to be fined $1 Billion for Lax Money Laundering ComplianceOn May 24, 2011 ∙ In HSBC, Money Laundering

August 2, 2012

The UK’s FSA fines Turkish Bank Ltd 294,000 pounds for weaknesses in its AML Program around correspondent accounts.

Key AML Program Components

29

Know

You

r Customer

Regulatory Oversight

Tran

saction Mon

itorin

gPe

riodic Tran

saction

Review

s

Sanctio

ns Screening

Periodic TrainingCompliance Program Governance & Metrics

Independent Audit, Internal Controls and TestingPolicies and Procedures

U.S. Due Diligence Reqs For FCB Accounts

30

General Due Diligence Requirements Enhanced Due Diligence Requirements Have a program to determine if the account is subject to

enhanced due diligence Assess the money laundering risk posed, based on relevant risk factors:

• The nature of the foreign financial institution’s business and the markets it serves.

• The type, purpose, and anticipated activity of the foreign correspondent account.

• The nature and duration of the bank’s relationship with the foreign financial institution (and, if relevant, with any affiliate of the foreign financial institution).

• The AML and supervisory regime of the jurisdiction that issued the charter or license to the foreign financial institution and, to the extent that information regarding such jurisdiction is reasonably available, of the jurisdiction in which any company that is an owner of the foreign financial institution is incorporated or chartered.

• Information known or reasonably available to the bank about the foreign financial institution’s AML record, including public information in standard industry guides, periodicals, and major publications.

Required when:

• Is the foreign correspondent bank operating under an offshore license?

• Does the FCB operate in a non‐cooperative or known money laundering jurisdiction?

• If the bank finds it appropriate to conduct additional due diligence measures based upon the results of its general due diligence program

Apply risk based policies, procedures, and controls• Detect and report suspected money laundering activity• Periodic review of activity

Conduct appropriate enhanced scrutiny

If the FCB offers correspondent banking services, conduct due diligence on those entities

Identify owners if not publicly traded

A bank’s KYC process should address these requirements.

Other global regulators have imposed similar standards for correspondent accounts

Citi’s KYC Components

31

AML RISK SUMMARY

APPENDIX

PTRTRP

CUSTOMER IDENTIFICATION PROGRAM (CIP)

SPF/PEP

PATRIOT ACT CERTIFICATE

(PAC)

AML COUNTRY REGIME

AML CALL REPORT

WOLFSBERG QUESTIONNAIRE

CLIENT OWNERSHIP

BUSINESS OPERATIONS

NEGATIVE NEWS

BOARD OF DIRECTORS AND SENIOR

MANAGEMENT

MARKET REPUTATION

AML CALL

APF


AML RISK SUMMARY

TRANSACTION ACTIVITY REVIEW


AML COUNTRY REGIME

AML CALL REPORT

32

CIP – Customer Identification Program

Sample Question

List any individuals who own 25% or more of the stake of your company.

If the entity is privately held and the owner is another legal entity, identify only the ultimate beneficial owners (i.e. the individuals at the top of the chain of ownership of the entity).

List any individuals who own 25% or more of the stake of your company.

If the entity is privately held and the owner is another legal entity, identify only the ultimate beneficial owners (i.e. the individuals at the top of the chain of ownership of the entity).

Common Answer

Banco XYZ SA is a privately held company. However, there are no individuals that, directly or indirectly,

hold 25% or more of Banco XYZ SA.

Banco XYZ SA is a privately held company. However, there are no individuals that, directly or indirectly,

hold 25% or more of Banco XYZ SA.

33

CIP – Customer Identification Program

Desired Answer

As per the ownership structure attached, Nicaragua nationals, Pepe, Lucas, Ramon, and Luisa individually hold 25% of Inverfin CR SA. At the same time Inverfin CR SA owns 80% of Banco XYZ.

As a result, all 4, Pepe, Lucas, Ramon, and Luisa, each indirectly hold 20% of the stake in Banco XYZ SA. The remaining 20% is directly owned by a fifth investor: Hernan.

As per the ownership structure attached, Nicaragua nationals, Pepe, Lucas, Ramon, and Luisa individually hold 25% of Inverfin CR SA. At the same time Inverfin CR SA owns 80% of Banco XYZ.

As a result, all 4, Pepe, Lucas, Ramon, and Luisa, each indirectly hold 20% of the stake in Banco XYZ SA. The remaining 20% is directly owned by a fifth investor: Hernan.

34


AML RISK SUMMARY



AML COUNTRY REGIME

AML CALL REPORT

35

Transaction Activity – Q&A #1

36

Sample Question

Please provide monthly anticipated volumes and values on the Citi NY correspondent account. Please provide monthly anticipated volumes and values on the Citi NY correspondent account.

Common Answer

Anticipated activity differs from PTR numbers.

Activity on the Citi NY correspondent account is expected to pick up by 20% during 2013.

Anticipated activity differs from PTR numbers.

Activity on the Citi NY correspondent account is expected to pick up by 20% during 2013.


37

Desired Answer

BANK XYZ has calculated an increase of 20% in the transaction activity for 2013.

This a result of an aggressive marketing campaign to create local brand awareness mainly through the

sponsorship of the XI Central American games in Panama City, Panama.

Our client has also become the official bank of the games' organization committee.

Transaction peaks will occur during the months that lead to the event as many international contracts

with builders, sports equipment providers, broadcasters, etc. need to be executed.

BANK XYZ has calculated an increase of 20% in the transaction activity for 2013.

This a result of an aggressive marketing campaign to create local brand awareness mainly through the

sponsorship of the XI Central American games in Panama City, Panama.

Our client has also become the official bank of the games' organization committee.

Transaction peaks will occur during the months that lead to the event as many international contracts

with builders, sports equipment providers, broadcasters, etc. need to be executed.


Sample Question

Please provide detailed information pertaining to top beneficiaries and originators of transactions (>5% volume or value):

The nature of business of the entity and relationship between the counterparties.

The expected purpose of the transactions.

The reason the payments were made in this manner (i.e. round dollar, consecutive days, etc.)

Is the activity expected to reoccur?

Any AML concerns with the activity

Please provide detailed information pertaining to top beneficiaries and originators of transactions (>5% volume or value):

The nature of business of the entity and relationship between the counterparties.

The expected purpose of the transactions.

The reason the payments were made in this manner (i.e. round dollar, consecutive days, etc.)

Is the activity expected to reoccur?

Any AML concerns with the activity

Common Answer

Banco XYZ initiated commercial transactions on behalf of one top originator customer: Softsilk SA,

Softsilk SA is a Salvadorian company dedicated to the production of fabrics.

Softsilk SA is a well regarded name at the local level and also a Citi client.

This transaction activity is expected to continue, no major AML issues have been raised.

Banco XYZ initiated commercial transactions on behalf of one top originator customer: Softsilk SA,

Softsilk SA is a Salvadorian company dedicated to the production of fabrics.

Softsilk SA is a well regarded name at the local level and also a Citi client.

This transaction activity is expected to continue, no major AML issues have been raised. 38


Desired Answer

Softsilk SA was identified as a top originator (more than 5% in volume) of transactions mainly to countries

located in the Middle East.

Softsilk LLC is an important Salvadorian textile producer. The client buys raw materials (threads) for the

production of fabrics to providers located in the Middle East.

Orders are placed monthly. Thus, the activity is recurrent.

Softsilk LLC has all export documentation that supports these transaction activity.

Softsilk LLC has been a client of BANK XYZ for more than 12 years.

Softsilk LLC is also subjected to Banco XYZ KYC process. Banco XYZ does not have any AML concerns with

this transaction activity. Furthermore, this is also an existing Citi client with an up to date file.

Softsilk SA was identified as a top originator (more than 5% in volume) of transactions mainly to countries

located in the Middle East.

Softsilk LLC is an important Salvadorian textile producer. The client buys raw materials (threads) for the

production of fabrics to providers located in the Middle East.

Orders are placed monthly. Thus, the activity is recurrent.

Softsilk LLC has all export documentation that supports these transaction activity.

Softsilk LLC has been a client of BANK XYZ for more than 12 years.

Softsilk LLC is also subjected to Banco XYZ KYC process. Banco XYZ does not have any AML concerns with

this transaction activity. Furthermore, this is also an existing Citi client with an up to date file.

39


AML RISK SUMMARY



AML COUNTRY REGIME

AML CALL REPORT

40

AML Call Report

41

AML Call Report

AML Transaction Monitoring

Special Risks of Client

Customer Due DiligenceInformation which is Known to or Reasonably Available to Citi about

the Client’s AML Record

AML Examinations and Audits

AML Program

Summarize findings and create Call Report

Highlight any Red Flags

Discuss any Issues with Compliance

Raise issues to the client as may be necessary

Comments and Conclusions

AML Call Report – Q&A #1

Sample Question

Describe the structure and staffing of the bank’s AML Department.

Please confirm the number of staff dedicated to AML related functions.

Describe the structure and staffing of the bank’s AML Department.

Please confirm the number of staff dedicated to AML related functions.

Common Answer

Banco XYZ compliance area is comprised of 9 employees. 5 of them are dedicated to AML related activities.

The Compliance officer has a manager rank and reports directly to the board of directors.

The Compliance officer has more than 10 years of experience.

Banco XYZ compliance area is comprised of 9 employees. 5 of them are dedicated to AML related activities.

The Compliance officer has a manager rank and reports directly to the board of directors.

The Compliance officer has more than 10 years of experience.

42


Desired Answer

Banco XYZ compliance area is comprised of 9 employees.

The compliance officer has a manager rank and reports directly to the board of directors.

She has more than 10 year of experience in Compliance and Controls areas. She has lead the Compliance unit for the past 4 years.

The AML department is a subdivision of the Compliance Unit and has direct oversight from the Compliance officer.

It is composed of 1 AML manager and 4 AML officers that are exclusively dedicated to the analysis of alerts that emanate from the automated transaction monitoring systems.

The number of analysts is adequate for the number of daily alerts raised by the monitoring system (around 50 daily alerts).

Furthermore, Banco XYZ has an adequate number of AML resources when compared to other local banks of the same size.

Banco XYZ compliance area is comprised of 9 employees.

The compliance officer has a manager rank and reports directly to the board of directors.

She has more than 10 year of experience in Compliance and Controls areas. She has lead the Compliance unit for the past 4 years.

The AML department is a subdivision of the Compliance Unit and has direct oversight from the Compliance officer.

It is composed of 1 AML manager and 4 AML officers that are exclusively dedicated to the analysis of alerts that emanate from the automated transaction monitoring systems.

The number of analysts is adequate for the number of daily alerts raised by the monitoring system (around 50 daily alerts).

Furthermore, Banco XYZ has an adequate number of AML resources when compared to other local banks of the same size.

43


Sample Question

Has the bank filed large currency transaction reports or suspicious activity reports to its local regulator in

the current year?

Has the bank filed large currency transaction reports or suspicious activity reports to its local regulator in

the current year?

Common Answer

Banco XYZ filed 7 suspicious activity reports during 2012. Banco XYZ filed 7 suspicious activity reports during 2012.

44


Desired Answer

Banco XYZ filed 7 suspicious activity reports (SARs) during 2012.

This shows a diminishing trend when compared to 2011 filings (11 SARs) and 2010 filings (15 SARs).

Diminishing trends can be explained by more hostile country environment for money launderers.

For example, the Central Bank has increased its requirements to justify recurrent and high value activity. Tougher laws that punish criminal activity have also been enacted in the country in the past 3 years.

Banco XYZ filed 7 suspicious activity reports (SARs) during 2012.

This shows a diminishing trend when compared to 2011 filings (11 SARs) and 2010 filings (15 SARs).

Diminishing trends can be explained by more hostile country environment for money launderers.

For example, the Central Bank has increased its requirements to justify recurrent and high value activity. Tougher laws that punish criminal activity have also been enacted in the country in the past 3 years.

45


AML RISK SUMMARY



AML COUNTRY REGIME

AML CALL REPORT

46

AML Country Regime – Country Reports

47

“… Although narcotics are still a major source of illegal proceeds for money laundering, the proceeds of other offenses, such as financial fraud and the smuggling of people and goods, have become increasingly important. …”

United Kingdom

Source: United States Department of State ‐ Bureau for International Narcotics and Law Enforcement Affairs ‐ International Narcotics Control Strategy Report


48

“… _______ is a major drug‐producing and drug‐transit country. Proceeds from the illicit drug trade leaving the United States are the principal source of funds laundered through the _______ financial system. Other significant sources of laundered proceeds include corruption, kidnapping, and trafficking in firearms and persons…”

Mexico



49

“… _______ is a major drug transit country and money laundering center. A multi‐billion dollar contraband trade, fed in part by endemic, institutional corruption, occurs in the border region shared with _______ and ________ and facilitates much of the money laundering.…”

Paraguay



50

“… _______ is a major cocaine‐transit country. The country‘s proximity to drug producing countries, weaknesses in its anti‐money laundering regime, limited bilateral cooperation, and substantial corruption in law enforcement and other relevant sectors continue to make _______ vulnerable to money laundering. The main sources of money laundering are proceeds generated by drug trafficking organizations and illegal transactions that exploit _______ currency controls and its various exchange rates…”

Venezuela



51

“… Money laundering in ________ is believed to be primarily related to the laundering of the proceeds of drug trafficking, and the country sits along major drug trafficking routes. The work of launderers is facilitated by weaknesses in the regulatory framework, notably the existence of bearer share corporations, but more importantly by uneven enforcement of anti‐money laundering measures and the weak judicial system, which is susceptible to corruption and favoritism…”

Panama



52

“… remains vulnerable to money laundering and other financial crimes, including various schemes that target U.S.‐based victims. Money laundering activities are primarily related to the foreign proceeds of international trafficking in cocaine. A sizeable internet gaming industry also launders millions of dollars in illicit proceeds through ____ and offshore centers annually. …”

Costa Rica



53Source: United States Department of State ‐ Bureau for International Narcotics and Law Enforcement Affairs ‐ International Narcotics Control Strategy Report

“… is a regional leader in the fight against money laundering and terrorist financing. … has a forceful anti‐money laundering/counter‐terrorist financing (AML/CFT) regime. …”

Colombia

“… however, the laundering of money from Colombia‘s illicit cocaine and heroin trade continues to penetrate its economy and affect its financial institutions. Laundered funds also are derived from commercial smuggling for tax and import duty evasion; kidnapping; arms trafficking; and terrorism connected to violent, illegally‐armed groups and guerrilla organizations, including U.S. Government‐designated terrorist organizations …”

Country reports

54

“… The major sources of money laundering proceeds include drug trafficking, fraud, loan-sharking (illegal money lending), remittance frauds, the black market economy, prostitution, and illicit gambling. …”

Japan

Source: United States Department of State - Bureau for International Narcotics and Law Enforcement Affairs - International Narcotics Control Strategy Report

Country reports

55

“… Historically weak law enforcement and judiciary systems coupled with endemic corruption and increasing organized crime activity contribute to a favorable climate for significant money laundering in …”

Guatemala

Source: United States Department of State - Bureau for International Narcotics and Law Enforcement Affairs - International Narcotics Control Strategy Report


AML RISK SUMMARY



AML COUNTRY REGIME

AML CALL REPORT

56

PTR & TRP

57

Features Periodic Transaction Review (PTR) Targeted Review Process (TRP)

Description

Review conducted on wire transactions flowing through US accounts of FCBs. Report summarizes activity and provides recommendations where differences are identified related to the client's KYC profile.

To supplement automated monitoring systems by assessing AML risk within FCBs US dollar accounts. It prioritizes the highest risk issues for in-depth review, analysis and potential action.

Purpose

Validate the accuracy of anticipated account activity, identify actual activity inconsistency with the client profile, identify high risk activity patterns and final validation of risk rating based on the activity analysis.

In-depth analysis conducted to review clients that meet certain qualitative and quantitative risk factors. This involves significant interaction between KYC Owners and Compliance

Frequency Conducted in the calendar month preceding the 90-day KYC renewal cycle

Performed on client that meet program criteria. This criteria includes but is not limited to the following:

SAR Reports Negative AML news New relationship and approved by CBOC

Time Covered in Review

Trailing 3 months of activity prior to the month of the PTR review

At least 3 months of wire activity but could be longer based on profile

Other Comments

All FCBs with a US account will be subject to a PTR

TRP are not conducted on all clients meeting Program criteria. Selection is based on a specific set of reviews and prioritization of higher risk items

Citi’s Expectations of its Clients

58

We look forward to a partnership with you during the KYC process.

We expect that when we have questions about your program and activity that

you will be responsive and forthcoming.

We expect that all of our clients have a robust AML Program that meets

regulatory and industry standards.

If we identify that a client’s AML program does not meet the mark it may

require remediation or account closings.

There is much more to do…

59

2011: United Nations Office on Drugs and Crime (UNODC)

2011: Less than 1 percent of global illicit financial flows is currently being seized and frozen

2012: 3.6% of $83.1 Tn = $3.0 Tn, 1% = 30 Bn

<1%

Source: UNODC – Estimating Illicit Flows Research Report ‐ 2011

Question & Answer Session

60

QUESTIONS?

Appendix

61

Preguntas Video

62 Source:

1. Para qué están hechas las reglas?

2. No sólo importa el tamaño del negocio, también importa ____

3. Qué información omitió Calvin escalar a su jefe

4. Qué elemento de trabajo de Calvin no se cumplió de acuerdo con el investigador?

Major Money Laundering Countries

63 Source: United States Department of State - Bureau for International Narcotics and Law Enforcement Affairs - International Narcotics Control Strategy Report

Countries/Jurisdictions of Primary Concern (66)Afghanistan France Liechtenstein United Arab EmiratesAntigua and Barbuda Germany Luxembourg United KingdomArgentina Greece Macau United StatesAustralia Guatemala Mexico UruguayAustria Guernsey Netherlands VenezuelaBahamas Guinea Nigeria ZimbabweBelize Haiti PakistanBolivia Hong Kong PanamaBrazil India ParaguayBritish Virgin Islands Indonesia PhilippinesBurma Iran RussiaCambodia Iraq SingaporeCanada Isle Of Man SomaliaCayman Islands Israel SpainChina, People Rep Italy St. MaartenColombia Japan SwitzerlandCosta Rica Jersey TaiwanCuracao Kenya ThailandCyprus Latvia TurkeyDominican Republic Lebanon Ukraine



Countries/Jurisdictions of Concern (68)Albania El Salvador Monaco SurinameAlgeria Ghana Mongolia SyriaAngola Gibraltar Montenegro TanzaniaAruba Grenada Morocco Trinidad and TobagoAzerbaijan Guyana Nicaragua Turks and CaicosBahrain Holy See Peru VanuatuBangladesh Honduras Poland VietnamBarbados Hungary Portugal YemenBelarus Ireland QatarBelgium Jamaica RomaniaBosnia and Herzegovina Jordan Saudi ArabiaBulgaria Kazakhstan SenegalChile Korea, North SerbiaComoros Korea, South SeychellesCook Islands Kosovo Sierra LeoneCote d'Ivoire Kuwait SlovakiaCzech Republic Laos South AfricaDjibouti Malaysia St. Kitts and NevisEcuador Marshall Islands St. LuciaEgypt Moldova St. Vincent



Other Countries/Jurisdictions Monitored (76)Andorra Eritrea Malta SloveniaAnguilla Estonia Mauritania Solomon IslandsArmenia Ethiopia Mauritius South SudanBenin Fiji Micronesia FS Sri LankaBermuda Finland Montserrat SudanBotswana Gabon Mozambique SwazilandBrunei Gambia Namibia SwedenBurkina Faso Georgia Nauru TajikistanBurundi Guinea Nepal Timor‐LesteCameroon Iceland New Zealand TogoCape Verde Kyrgyz Republic Niger TongaCentral African Republic Lesotho Niue TunisiaChad Liberia Norway TurkmenistanCongo, Dem Rep Of Libya Oman UgandaCongo, Rep Of Lithuania Palau UzbekistanCroatia Macedonia Papua New Guinea ZambiaCuba Madagascar RwandaDenmark Malawi SamoaDominica Maldives San MarinoEquatorial Guinea Mali Sao Tome & Principe

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