1.
FATF Recommendations
Understand the 40 FATF Recommendations on AML/CFT.
Key areas:
o Customer Due Diligence (CDD) / Know Your Customer (KYC)
o Beneficial ownership identification
o Record-keeping requirements
o Reporting suspicious transactions
o Politically Exposed Persons (PEPs)
o Cross-border wire transfers
o Reporting obligations to Financial Intelligence Units (FIUs)
Practical application: How institutions implement FATF guidance in
policies, risk assessments, and transaction monitoring.
2. AML/CFT International Standards
Basel Committee guidelines
o Bank supervision and risk-based approach
o Internal controls and independent audits
UN Conventions
o Vienna Convention (1988) – Narcotics trafficking
o Palermo Convention (2000) – Transnational Organized Crime
o Terrorist Financing Conventions
ISO 37001 & ISO 31000 (for risk management and anti-bribery,
optional but useful context)
EU Directives (for European context, optional for global
understanding)
3. Risk-Based Approach (RBA)
Understand how to:
o Identify customer and product risk
o Apply enhanced due diligence (EDD) for high-risk customers
o Monitor transactions proportionate to risk
How to incorporate risk-based controls in policies and monitoring
systems
4. AML/CFT Program Components
Compliance Program Elements
o Internal policies, procedures, and controls
o Appointment of compliance officer
o Independent testing/audit of program
o Training and awareness for staff
Customer Risk Profiling and Ongoing Monitoring
o Red flags and suspicious transaction identification
o SAR/STR filing process
5. Sanctions and Politically Exposed Persons (PEPs)
Global sanctions lists (UN, OFAC, EU)
Screening and monitoring techniques
Risk mitigation for high-risk jurisdictions
6. Suspicious Activity Reporting (SAR/STR)
Reporting obligations and thresholds
Internal escalation procedures
Maintaining confidentiality and legal protections
7. Practical Application & Case Studies
Recognize AML red flags in:
o Deposits, withdrawals, wire transfers
o Structuring or smurfing
o Unusual patterns or inconsistent customer behavior
How to document and escalate findings
8. Other Relevant Topics
Emerging risks:
o Cryptocurrencies and virtual assets
o Money laundering through fintech, EMIs, and MSPs
AML technology:
o Transaction monitoring systems
o KYC/CDD automation