© ACAMS. All rights reserved. This information is subject to change.

FinTechs as Your Customers course syllabus updated 17MAR2019 1

FINTECHS AS YOUR CUSTOMERS

Course Syllabus

Objective

The objective of this course is to raise awareness and enhance the existing knowledge of financial institution compliance teams about FinTech businesses as both potential and existing customers.

The course will provide insight into the operational aspects of different types of FinTech businesses and the potential inherent financial crime (“FC”) risks they can face. The course will also explore the unique FinTech approaches to onboarding, transaction monitoring and data storage and how these can affect business relationships.

The target outcome of the course will be to provide compliance professionals with the tools needed so that Financial Institutions (“FIs”) can appropriately and effectively establish business relationships with FinTechs and demonstrate a solid understanding of their risk profiles, from an FC perspective..

Audience

The primary target audience is compliance professionals from conventional FIs (banks, insurers, investment sector), trust and corporate services providers, and money service businesses; consultants working with conventional FIs; regulatory staff in AML and related supervisory functions; members of FI intelligence/ investigation teams; outsourcing partners providing KYC/CDD/Customer Risk Assessment support; FI policy oversight/audit/assurance team members; and law enforcement.

The course was co-written and will be presented by subject matter experts with working knowledge of FinTech businesses. It draws on real life operational experiences and emerging financial crime typologies encountered when serving FinTech customers. The course was reviewed by conventional FI representatives to ensure relevance.

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FinTechs as Your Customers course syllabus updated 17MAR2019 2

Course Structure

Assignment Format Download from LMS

Week 1 90 mins – VIRTUAL CLASSROOM

Live event: See LMS for date/time. Later a recording will be on the LMS.

PDF slides

Week 2 90 mins – VIRTUAL CLASSROOM

Live event: See LMS for date/time. Later a recording will be on the LMS.

PDF slides

Week 3 30 mins – HOMEWORK 30 mins – ONLINE ASSESSMENT

Self-paced, available anytime. Self-paced, available anytime.

PDF Assignment PDF ACAMS Certificate

To earn the certificate you must pass the assessment within the 4 weeks. The assessment has 20 questions. The minimum passing score is 80%. Multiple attempts are allowed. When you pass, your ACAMS Certificate will be available in the learning path itself. Click to download a PDF. ACAMS will automatically add 4 CAMS Credits to your profile.

Technical Requirements:

The course is compatible with most operating systems and browsers to make it easy to participate. The course is mobile-friendly. The ACAMS Learning Management System (LMS) is https://lms.acams.com. Contact your organization’s IT department for assistance.

© ACAMS. All rights reserved. This information is subject to change.

FinTechs as Your Customers course syllabus updated 17MAR2019 3

Behavioral outcomes of this course:

1. Understand the business model and operating culture of FinTechs

2. Recognize the financial crime risks inherent to FinTechs

3. Identify and understand the controls used by FinTechs to mitigate risk

4. More effectively manage relationships with FinTechs as customers and businesspartners

Course content

WEEK 1 Overall Time: 1.5 hours

Content

Section 1 Introduction

a. Key learning objectives

b. What is a “FinTech”?

i. Establish parameters for categorising a business as a “FinTech”

ii. Clarify features which characterise subgroups of FinTech businesses

c. FinTechs: Business Models and Operating Culture

i. Explore the Continuum of FinTech business models

ii. Review characteristics Fintech operating cultures

iii. Insight as to how these factors influence AFC compliance

iv. Assumptions and errors made about FinTech culture and operations

Section 2 Financial crime and the FinTech sector

d. Financial crime (FC) risk areas to which FinTechs may be exposed including:

i. Fraud

ii. Money Laundering

iii. Terrorist Financing

iv. Cybercrime

v. Other forms of financial crime

e. Factors that may make FinTechs vulnerable to being targeted for misuse by criminals

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FinTechs as Your Customers course syllabus updated 17MAR2019 4

Section 3 a. Understanding the possible financial crime risks in a FinTech’s business model

b. Canvass inherent FC risks relative to a FinTech’s business model

i. Detailed review of FinTech-specific characteristics relevant to:

ii. Customer risks

iii. Jurisdiction risks

iv. Product and Services risks

v. Channel of Delivery risks

vi. Other – culture, regulatory status, outsourcing of KYC activities, screening etc.

Case Guided case study

WEEK 2 Overall Time: 1.5 hours

Content

Section 1 Introduction

a. Recap of key messages from Day 1

b. Learning Objectives for Day 2

Section 2 Understanding the difference in and evolution of controls used by FinTechs to mitigate financial crime

risks and store customer data

1. Onboarding / Know Your Customer / Customer Due Diligence

a. Types of KYC processes used by FinTechs

b. In-house vs. Outsourced KYC solutions

c. New technologies in FinTech KYC

i. Selfie matching / Liveliness checks

ii. Biometric screening

iii. Customer life-cycle

iv. Policy automation

v. New data points – IP, locations, device IDs

d. Understanding the nature and purpose of customer relationships and projecting customer business activity

e. Strategies and tools for risk rating customers

f. Assumptions and errors made by people about KYC / CDD undertaken by FinTechs

2. Ongoing Monitoring and Screening

a. Methodology applied by FinTechs to screen customers

b. Transaction monitoring tools and strategies used by FinTechs

c. In-house vs. Outsourced monitoring and screening tools

d. Tech solutions for ongoing screening and monitoring

e. e. g. Machine learning

f. Assurance models to verify effective business relationship checks

g. Assumptions and errors made about monitoring and screening undertaken by FinTechs

© ACAMS. All rights reserved. This information is subject to change.

FinTechs as Your Customers course syllabus updated 17MAR2019 5

Section 2 3. Record Retention and Data Storage

a. How FinTechs gather data from their customers

b. What data FinTechs gather

c. In-house vs. Outsourced data retention offerings

d. Tech solutions for retaining customer data

e. How to understand back-end data at a FinTech

f. Regulatory developments in data retention at FinTechs

g. Assumptions and errors made about FinTech data storage and retention practices

Section 3 Effective relationship management with your FinTech customers

a. Strategies to replace de-risking

b. Best and worst practices in FinTech / FI relationships

c. Opportunities for better FinTech / FI engagement

Case Guided case study

WEEK 3 Overall Time: 30 minutes

Content

Case Study Home Work Assignment

WEEK 4 Overall time: 30 minutes

Content

Final Assessment Exam