Onfido – The Risks of Not Carrying out Background Checks

Through carrying out background checks, employers have the ability to verify a candidate’s identity, history and suitability for a job role. Checking a candidate’s identity is the most fundamental form of check. This involves simply verifying that a candidate is who they say are; in other words, making sure that they are not using fake documentation to commit identity fraud. Identity checks, along with right to work checks, are crucial no matter what industry the candidate is applying to work in.

At Onfido, these checks are classified into 3 basic categories:


1) Confirm your applicant’s IDENTITY 


Identity Report

Identity Reports are crucial to the background checking process. Unless you know a person is who they say they are, any other information you receive from them (e.g. the results of a criminal record check or their qualifications) cannot be relied upon.

Onfido’s Identity Reports will verify an applicant’s:

    • Address Details
    • Previous Addresses
    • Date of Birth
    • Mortality
    • Passport Number Validity

Right to Work Report

It is a criminal offence to employ a person who does not have the right to work in the UK. The UK Border Agency will fine an employer up to £10,000 if an illegal migrant worker is found working for them.

Onfido’s technology analyses passports to verify that they are not lost, stolen or compromised. Onfido also validates visa documentation to confirm whether or not your applicant has the right to work in the UK.


 2) Confirm your applicant’s HISTORY 


Adverse History Report

For roles that involve a high degree of trust, an adverse financial history (such as a County Court Judgment) is statistically associated with candidates who abuse their position for personal financial gain. These risks apply to low skilled workers who enter a client’s premises (e.g. cleaners), in addition to more typically fiduciary positions such as accountants. Onfido access the Dow Jones watchlist as well as over 60 other global sanctions lists to highlight whether your applicant has any red flags in their history.

The information contained in Onfido’s Adverse History Reports includes:

    • County Court Judgments
    • Court Judgments at Linked Addresses
    • Bankruptcy and Insolvency
    • Individual Voluntary Arrangement
    • Halo Register
    • Sanctions and Politically Exposed Persons
    • Negative Media Checks
    • Current and Previous Directorship Details

Criminal History Report

Disclosure Scotland and Disclosure and Barring Service (DBS) checks, formerly known as CRB checks, are legally required for certain positions (e.g. working with children and vulnerable adults). Failure to comply will not only lead to fines, but can potentially put the safety of the public at risk. In other circumstances, DBS checks are advisable in order to reduce the risk of employee fraud (e.g. if the candidate has a string of past convictions for theft).

Basic Disclosure | Standard Disclosure | Enhanced Disclosure


3) Confirm your applicant’s SUITABILITY 

This includes checking that they have not embellished details about their education and qualifications, or provided fake references in order to try and boost their application. This is more important in high-skill roles where qualifications and references are crucial to the application process.

Education and Qualifications Report

Onfido’s technology confirms that education and qualification certificates are genuine through checking directly with the issuing establishment.

The information contained in Onfido’s Education and Qualifications Reports includes confirmation of:

    • Institution attended
    • Course Title
    • Degree Type
    • Classification
    • Dates attended

Employment and Reference Report

Onfido allows you to create customised reference questionnaires so that you can receive the information you require from an applicant’s referees and previous employers.

The information contained in our Employment and Reference Report includes:

    • Employer verification of applicant’s employment history
    • Employer responses to basic questions about the applicant
    • Referee responses to customised questionnaire
    • 5 year employment timeline with supporting documentation for any gaps over 28 days.

For more information on Onfido’s reports see: https://onfido.co.uk/reports

The following infographic shows the Risks of Not Carrying out Background Checks

Onfido Infographic - Risks of Not Carrying out Background Checks

Onfido – Why should you do Background checks?

The recent story of Mark Harper, the UK Immigration minister who had to resign from his post after it emerged that his cleaner did not have permission to work in the UK, serves as a clear reminder of the need for rigorous background checks of employees. While it may seem like yet another dull administrative hoop to jump through, the importance to employers of verifying matters such whether an applicant has the right to work in the UK and is suitably a qualified for a role is obvious. The statistics are shocking: a staggering 21% of that applicants that we process typically provided false information about a degree, provided false employers or fabricated non-existent jobs. It is estimated that there are over 860,000 illegal migrant workers in the UK.

At the moment, the UK Border Agency will fine a company £10,000 for every illegal migrant worker being employed; £57.5 million in fines were handed out to the end of 2012. Despite this huge figure, the new Immigration Bill looks to double the maximum penalty for employing illegal migrant workers from £10,000 per worker to £20,000. Not only are such fines likely to place significant financial pressure on anyone found to be employing illegal cleaners, but the business’ details can also be published by the UK Border Agency as a warning to other businesses not to employ illegal workers, which can be devastating for the reputation of a cleaning company. Stricter still, the employer can be jailed for up to two years and receive an unlimited fine if they were to knowingly employ an illegal worker.

The infographic below shows the importance of Identity checks:


      In addition to right to work checks, there are of course other checks that should be carried out on a candidate. Right to work checks are so crucial because not only do they affect every UK employer, but they are also a legal obligation. Some forms of background check are legally required depending on the industry, whilst others are not legal requirements but are strongly recommended.  

For more information see: onfido.co.uk

US Ukraine Sanctions – 11 names – E.O. 13660 – 17 March 2014

United-States-Flag-128 Russia-Flag Ukraine-Flag-128

President Obama today (17 March 2014)  issued a new Executive Order (E.O.) under the national emergency with respect to Ukraine that finds that the actions and policies of the Russian government with respect to Ukraine -– including through the deployment of Russian military forces in the Crimea region of Ukraine –- undermine democratic processes and institutions in Ukraine; threaten its peace, security, stability, sovereignty, and territorial integrity; and contribute to the misappropriation of its assets.

This new authority expands upon E.O. 13660, which the President signed less than two weeks ago, by authorizing the Secretary of the Treasury, in consultation with the Secretary of State, to impose sanctions on named officials of the Russian government, any individual or entity that operates in the Russian arms industry, and any designated individual or entity that acts on behalf of, or that provides material or other support to, any senior Russian government official.  We have fashioned these sanctions to impose costs on named individuals who wield influence in the Russian government and those responsible for the deteriorating situation in Ukraine.  We stand ready to use these authorities in a direct and targeted fashion as events warrant.

In response to the Russian government’s actions contributing to the crisis in Ukraine, this new E.O. lists seven Russian government officials who are being designated for sanctions.  These individuals are Vladislav Surkov, Sergey Glazyev, Leonid Slutsky, Andrei Klishas, Valentina Matviyenko, Dmitry Rogozin, and Yelena Mizulina.

The United States also will seek to hold accountable individuals who use their resources or influence to support or act on behalf of senior Russian government officials.  We recognize that the Russian leadership derives significant support from, and takes action through, individuals who do not themselves serve in any official capacity.  Our current focus is to identify these individuals and target their personal assets, but not companies that they may manage on behalf of the Russian state.

In addition to the new E.O., the Treasury Department today has imposed sanctions on four other individuals under E.O. 13660, issued on March 6, for their actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine and in undermining the Government of Ukraine.  They are Crimea-based separatist leaders Sergey Aksyonov and Vladimir Konstantinov; former Ukrainian presidential chief of staff Viktor Medvedchuk; and former President of Ukraine Viktor Yanukovych.

Today’s actions send a strong message to the Russian government that there are consequences for their actions that violate the sovereignty and territorial integrity of Ukraine, including their actions supporting the illegal referendum for Crimean separation.  The United States, together with international partners, will continue to stand by the Ukrainian government to ensure that costs are imposed on Crimean separatists and their Russian backers.  Today’s actions also serve as notice to Russia that unless it abides by its international obligations and returns its military forces to their original bases and respects Ukraine’s sovereignty and territorial integrity, the United States is prepared to take additional steps to impose further political and economic costs.

    • Vladislav Surkov:  Surkov is being sanctioned for his status as a Presidential Aide to Russian President Vladimir Putin.
    • Sergey Glazyev:  Glazyev is being sanctioned for his status as a Presidential Adviser to Russian President Vladimir Putin
    • Leonid Slutsky:  Slutsky is being sanctioned for his status as a State Duma deputy, where he is Chairman of the Duma Committee on CIS Affairs, Eurasian Integration, and Relations with Compatriots.
    • Andrei Klishas:  Klishas is being sanctioned for his status as a Member of the Council of Federation of the Federal Assembly of the Russian Federation and as Chairman of the Federation Council Committee of Constitutional Law, Judicial, and Legal Affairs, and the Development of Civil Society.
    • Valentina Matviyenko:  Matviyenko is being sanctioned for her status as Head of the Federation Council
    • Dmitry Rogozin:  Rogozin is being sanctioned for his status as the Deputy Prime Minister of the Russian Federation.
    • Yelena Mizulina:  Mizulina is being sanctioned for her status as a State Duma Deputy.
    • Sergey Aksyonov:  Aksyonov is being designated for threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine, and for undermining Ukraine’s democratic institutions and processes.  Aksyonov claims to be the Prime Minister of Crimea and has rejected the authority of the legitimate government in Kyiv.
    • Vladimir Konstantinov:  Konstantinov is being designated for threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine, and for undermining Ukraine’s democratic institutions and processes.  Konstantinov is the speaker of the Crimean parliament, which on March 11, 2014, declared independence from Ukraine.
    • Viktor Medvedchuk:  Medvedchuk, leader of Ukrainian Choice, is being designated for threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine, and for undermining Ukraine’s democratic institutions and processes.  He is also being designated because he has materially assisted, sponsored, or provided financial, material, or technological support to Yanukovych and because he is a leader of an entity that has, or whose members have, engaged in actions or policies that undermine democratic processes or institutions in Ukraine and actions or policies that threaten the peace, security, stability, sovereignty, or territorial integrity of Ukraine.
    • Viktor Yanukovych:  Former Ukrainian President Yanukovych is being designated for threatening the peace, security, stability, sovereignty, or territorial integrity of Ukraine, and for undermining Ukraine’s democratic institutions and processes.  After abandoning Kyiv and ultimately fleeing to Russia, Viktor Yanukovych called upon Russian President Vladimir Putin to send Russian troops into Ukraine.

Source: http://www.whitehouse.gov/the-press-office/2014/03/17/fact-sheet-ukraine-related-sanctions

EU Ukraine Sanctions – 21 names – EU Official Journal 17 March 2014

European Union - External Action

The Council of the European Union

17 March 2014

EU adopts restrictive measures against actions threatening Ukraine’s territorial integrity

The Council adopted EU restrictive measures against persons responsible for actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine as well as persons and entities associated with them.

In this regard, 21 persons have been identified and targeted with a travel ban and a freeze of their assets within the EU. The sanctions enter into force on 17 March, 2014 following publication of the legal acts with the list of persons concerned in the EU Official Journal (See below).

The list of persons are as follows:

Sergey Valeryevich Aksyonov  – Aksyonov was elected “Prime Minister of Crimea” in the Crimean Verkhovna Rada on 27 February 2014 in the presence of pro-Russian gunmen. His “election” was decreed unconstitutional by Oleksandr Turchynov on 1 March. He actively lobbied for the “referendum” of 16 March 2014.

Vladimir Andreevich Konstantinov – As speaker of the Supreme Council of the Autonomous Republic of Crimea, Konstantinov played a relevant role in the decisions taken by the Verkhovna Rada concerning the “referendum” against territorial integrity of Ukraine and called on voters to cast votes in favour of Crimean Independence.

Rustam Ilmirovich Temirgaliev – As Deputy Chairman of the Council of Ministers of Crimea, Temirgaliev played a relevant role in the decisions taken by the Verkhovna Rada concerning the “referendum” against territorial integrity of Ukraine. He lobbied actively for integration of Crimea into the Russian Federation.

Deniz Valentinovich Berezovskiy – Berezovskiy was appointed commander of the Ukrainian Navy on 1 March 2014 and swore an oath to the Crimean armed force, thereby breaking his oath. The Prosecutor-General’s Office of Ukraine launched an investigation against him for high treason.

Aleksei Mikhailovich Chaliy – Chaliy became “Mayor of Sevastopol” by popular acclamation on 23 February 2014 and accepted this “vote”. He actively campaigned for Sevastopol to become a separate entity of the Russian Federation following a referendum on 16 March 2014.

Pyotr Anatoliyovych Zima – Zima was appointed as the new head of the Crimean Security Service (SBU) on 3 March 2014 by “Prime Minister” Aksyonov and accepted this appointment. He has given relevant information including a database to the Russian Intelligence Service (SBU). This included information on Euro-Maidan activists and human rights defenders of Crimea. He played a relevant role in preventing Ukraine’s authorities from controlling the territory of Crimea. On 11 March 2014 the formation of an independent Security Service of Crimea has been proclaimed by former SBU officers of Crimea.

Yuriy Zherebtsov – Counsellor of the Speaker of the Verkhovna Rada of Crimea, one of the leading organizers of the 16 March 2014 “referendum” against Ukraine’s territorial integrity.

Sergey Pavlovych Tsekov – Vice Speaker of the Verkhovna Rada; Tsekov initiated together with Sergey Aksyonov the unlawful dismissal of the government of the Autonomous Republic of Crimea (ARC). He drew into this endeavour Vladimir Konstantinov, threatening him with his dismissal. He publicly recognized that the MPs from Crimea were the initiators of inviting Russian soldiers to take over Verkhovna Rada of Crimea. He was one of the first Crimean Leaders to ask in public for annexation of Crimea to Russia.

Ozerov, Viktor Alekseevich  – Chairman of the Security and Defense Committee of the Federation Council of the Russian Federation. On 1 March 2014 Ozerov, on behalf of the Security and Defense Committee of the Federation Council, publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Dzhabarov, Vladimir Michailovich – First Deputy-Chairman of the International Affairs Committee of the Federation Council of the Russian Federation. On 1 March 2014 Dzhabarov, on behalf of the International Affairs Committee of the Federation Council, publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Klishas, Andrei Aleksandrovich – Chairman of the Committee on Constitutional Law of the Federation Council of the Russian Federation. On 1 March 2014 Klishas publicly supported in the Federation Council the deployment of Russian forces in Ukraine. In public statements Klishas sought to justify a Russian military intervention in Ukraine by claiming that “the Ukrainian President supports the appeal of the Crimean authorities to the President of the Russian Federation on landing an all-encompassing assistance in defense of the citizens of Crimea.”

Ryzhkov, Nikolai Ivanovich – Member of the Committee for federal issues, regional politics and the North of the Federation Council of the Russian Federation. On 1 March 2014 Ryzhkov publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Bushmin, Evgeni Viktorovich – Deputy Speaker of the Federation Council of the Russian Federation. On 1 March 2014 Bushmin publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Totoonov, Aleksandr Borisovich – Member of the Committee on culture, science, and information of the Federation Council of the Russian Federation. On 1 March 2014 Totoonov publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Panteleev, Oleg Evgenevich – First Deputy Chairman of the Committee on Parliamentary Issues. On 1 March 2014 Panteleev publicly supported in the Federation Council the deployment of Russian forces in Ukraine.

Mironov, Sergei Mikhailovich – Member of the Council of the State Duma; Leader of Fair Russia faction in the Duma of the Russian Federation. Initiator of the bill allowing Russian Federation to admit in its composition, under the pretext of protection of Russian citizens, territories of a foreign country without a consent of that country or of an international treaty.

Zheleznyak, Sergei Vladimirovich – Deputy Speaker of the State Duma of the Russian Federation. Actively supporting use of Russian Armed Forces in Ukraine and annexation of Crimea. He led personally the demonstration in support of the use of Russian Armed Forces in Ukraine.

Slutski, Leonid Eduardovich – Chairman of the Commonwealth of Independent States (CIS) Committee of the State Duma of the Russian Federation (member of the LDPR). Actively supporting use of Russian Armed Forces in Ukraine and annexation of Crimea.

Vitko, Aleksandr Viktorovich – Commander of the Black Sea Fleet, Vice-Admiral.  Responsible for commanding Russian forces that have occupied Ukrainian sovereign territory.

Sidorov, Anatoliy Alekseevich – Commander, Russia’s Western Military District, units of which are deployed in Crimea. Commander of Russia’s Western Military District,units of which are deployed in Crimea. He is responsible for part of the Russian military presence in Crimea which is undermining the sovereignty of the Ukraine and assisted the Crimean authorities in preventing public demonstrations against moves towards a referendum and incorporation into Russia.

Galkin, Aleksandr – Russia’s Southern Military District, forces of which are in Crimea; the Black Sea Fleet comes under Galkin’s command; much of the force movement into Crimea has come through the Southern Military District. Commander of Russia’s Southern Military District (“SMD”). SMD forces are deployed in Crimea. He is responsible for part of the Russian military presence in Crimea which is undermining the sovereignty of the Ukraine and assisted the Crimean authorities in preventing public demonstrations against moves towards a referendum and incorporation into Russia. Additionally the Black Sea Fleet falls within the District’s control.



See: http://kycmap.com/EU-Ukraine-sanctions-list-17march2014.pdf 

Swiss Govt Sanctions on Viktor Yanukovych & Ukraine Persons – Feb 2014

Ukraine-Flag-128 Switzerland-Flag-128

The Swiss Federal Council has decided to block all assets of Viktor Yanukovych and his entourage might have in Switzerland. The corresponding ordinance enters into force on Friday 28 February, 2014. In taking this measure, the Federal Council wishes to avoid any risk of misappropriation of Ukrainian state assets.

In view of the most recent developments, the Federal Council wishes to take all measures necessary to avoid the risk of any misappropriation of financial assets of the Ukrainian state. It has therefore decided, in conjunction with other financial centres, to block all assets Viktor Yanukovych and his entourage might have in Switzerland. The Federal Council has also prohibited the sale and any disposal of assets, namely property, of these persons. The aim of this measure is to prevent these assets being taken out of Switzerland before they can be blocked through the ordinary channels of mutual legal assistance in cooperation with the Ukrainian authorities.

The below listed names are listed in English spelling:

Serhiy Hennadiyovych ARBUZOV, born on 24th March 1976 - Former Prime Minister

Mykola (Nikolai) Yanovych AZAROV (Born as Nikolai Yanovich Pakhlo)born on 17 December 1947, Prime Minister Jan 2014

Raisa Vasylivna BOHATYROVA (BOGATYROVA) born on 6 January 1953, former Health Minister

Mykhaylo (Mikhail) Markovych DOBKIN, born on 26 January 1970 - Governor of Privonz Kharkiv (Kharkov), founder of the Ukrainian Front

Yuriy IVANYUSHCHENKO, born on 21 February 1959, Member of Parliament, a close confidant of Viktor Yanukovych

Hennadiy Adolfovych KERNES, born on 27 June 1959, Mayor of Kharkiv (Kharkov)

Oleksandr Viktorovych KLYMENKO, born on 16th November 1980 - former Minister of Income and Taxes

Andriy Petrovych KLYUYEV (Andrey KLUEV / Klyuev), born on 12 August 1964, former chief of the President’s Division

Serhiy Petrovych KLYUYEV (KLUEV / Klyuev), born on 12 August 1969, Businessman, brother of Andriy Klyuyev

Borys Viktorovych KOLESNIKOV, born on 25 October 1962, former Infrastructure minister at the time of European Football Championship EURO 2012

Yuriy Volodymyrovych KOLOBOV, born on 8 April 1973 former Finance Minister

Volodymyr Vasylovych KOZAK, born on 9 August 1959, former Minister for Infrastructure

Olena Leonidivna LUKASH, born on 12 November 1976 former Minister of Justice

Mykola Volodymyrovych PRYSYAZHNYUK, born on 3 January 1960, former Minister of Agricultural Policy and Food Industry

Viktor Pavlovych PSHONKA, born on 6 February 1954, former Attorney General

Eduard Anatoliyovych STAVYTSKY, born on 4 October 1972 -Former Minister of Energy and Coal Industry

Oleksandr (Aleksandr) Viktorovych YANUKOVYCH, who was born on 1 July 1973 - Son of the former president, Businessman

Viktor Fedorovych YANUKOVYCH was born on 9 July 1950, Former President

Oleksandr (Aleksandr) Serhiyovych YEFREMOV, born on 22 August 1954, Leader of the Party of Regions

Vitaly Yuriyovych ZAKHARCHENKO, born on 20 January 1963, former Minister of the Interior

See: Swiss Ukraine Sanctions List Feb 26 2014

Source: Swiss Federal Council Press Release


ACAMS 10th Annual AML & Financial Crime Conference



The ACAMS 10th Annual AML & Financial Crime Conference is taking place 29-30 May in London, will host industry’s most influential financial crime experts. Join us for the region’s premiere forum on critical topics ̶ including the EU Money Laundering Directive, international tax initiatives, trade and economic sanctions and virtual attacks.

This year’s assembly of influential thought-leaders includes:

    • Fabrice Borsello, Chief AML Risk Officer and Vice President, Western Union
    • James Cadwallader, Global Head of Intelligence and Analysis, Financial Crime Risk Operations, Standard Chartered
    • Tim Goodrick, AML/CFT Policy Analyst, Financial Action Task Force
    • Gerard Green, Head of AML – Europe, Middle East and Americas, Franklin Templeton Investments
    • Charles Monteith, Head of Legal and Case Consultancy, Basel Institute on Governance
    • Samantha J. Sheen, Head of Financial Crime and Authorisations Division,Guernsey Financial Services Commission


Topics to be discussed are:

    • Implementing a Robust AML Risk Assessment Process
    • Mitigating the Money Laundering Risks of Trade Finance
    • Leveraging Your Existing Compliance Programme in Response to Extraterritorial Tax Initiatives
    • Preparing for the Fourth Directive and its Impact on Your Institution
    • Applying Advanced Data Analytics to Improve Financial Crime Intelligence
    • Building a Compliance Framework for Complex Trade and Economic Sanctions Regimes
    • Financial Crime Trend Watch: Exposing the Latest Typologies and Preparing for New Schemes
    • Cyber Crime Update: Fortifying Your Institution Against Virtual Attacks

For the ACAMS 10th Annual AML & Financial Crime Conference Program Details see: http://www.amleurope.org/programme.asp


Algeria – Know Your Customer (KYC) Rules



The extent of money laundering through formal financial institutions in Algeria is thought to be minimal due to stringent exchange control regulations, a large segment of the economy that is cash-based, and an antiquated banking sector dominated by public banks. The restricted convertibility of the Algerian dinar enables the Central Bank to monitor all international financial operations carried out by public and private banking institutions. Notable criminal activity includes trafficking, particularly of drugs and cigarettes, but also arms and stolen vehicles; kidnapping for ransom (KFR); theft; extortion; and embezzlement. Public corruption remains a serious concern as does terrorism. Algerian authorities are increasingly concerned by cases of customs fraud and trade-based money laundering. Other risk areas for financial crimes include unregulated alternative remittance and currency exchange systems, tax evasion, abuse of real estate transactions, commercial invoice fraud, and a cash-based economy. Most money laundering is believed to occur primarily outside the formal financial system, given the large percentage of financial transactions occurring in the informal gray and black economies in general. Al-Qaida in the Islamic Maghreb, which originated in Algeria, is currently confined to outlying areas but has a history of terrorist activity in Algiers and elsewhere in the country, including suicide attacks, KFR, roadside bomb attacks, and assassinations.




Enhanced due diligence procedures for PEPs:


PEP is an abbreviation for Politically Exposed Person, a term that describes a person who has been entrusted with a prominent public function, or an individual who is closely related to such a person. The terms PEP, Politically Exposed Person and Senior Foreign Political Figure are often used interchangeably

    • Foreign PEP: YES
    • Domestic PEP: NO

Algeria - KYC covered entities


The following is a list of Know Your Customer entities covered by Algerian Law:


    • Banks
    • Financial leasing institutions
    • Investment and shareholding companies

Algeria - Suspicious Transaction Reporting (STR) Requirements:

Number of STRs received and time frame:  1,373 in 2012

The following is a list of STR covered entities covered by Algerian Law:

    • Banks
    • Financial leasing institutions
    • Investment and shareholding companies
    • Real estate agents
    • Car dealers
    • Other financial professionals who advise or carry out transactions, such as deposits, exchanges, or other movements of capital

Algeria is a member of the Middle East and North Africa Financial Action Task Force (MENAFATF), a Financial Action Task Force-style regional body.


In 2012, the Government of Algeria (GOA) implemented a package of policies intended to diminish the informal sector, motivate Algerian business people to formalize their activities, and generate revenue for the central government. A new law enacted in February 2012 extends the scope of KYC obligations to all financial institutions and expands the list of professionals who must report suspicious activity to include real estate agents, car dealers, and financial professionals who advise or carry out transactions, such as deposits, exchanges, and other movement of capital. The law also gives the GOA the authority to freeze and/or seize assets belonging to or destined for terrorists or a terrorist organization for a renewable one-month period. However, the administrative processes associated with this new authority remain unclear, while the corresponding judiciary processes appear not to conform to international standards. The GOA should move forward with the implementation of these laws, issue implementing regulations where required, and continue to work to address the remaining deficiencies in its anti-money laundering/counter-terrorist financing regime.

Specifically, the GOA should take significant legislative action to criminalize the financing of terrorism for any purpose, i.e., regardless of a link to the planning or commission of a terrorist act, and to establish a formal legal framework to implement the targeted financial sanctions included in UNSCRs 1267 and 1373. According to the director of the Algerian Financial Intelligence Cell (CTRF), the financial intelligence unit, the GOA is in the process of developing legislation that would criminalize terrorist finance even where unconnected to a terrorist act. This legislation was delayed by the Algerian President’s medical crisis.

The CTRF should be the focal point for receiving and analyzing suspicious activity reports, and for the exchange of information regarding suspicious transactions related to money laundering/terrorist financing activity. This will require the CTRF to develop in-house analytical and information technology capabilities. The CTRF should continue outreach to the formal and informal financial sectors. In addition, given the scope of Algeria’s informal economy, new efforts should be made to identify value transfer mechanisms not covered by Algeria’s legal and regulatory framework. Algerian law enforcement and customs authorities should enhance their ability to investigate trade-based money laundering, value transfer, and bulk cash smuggling used to finance terrorism and other illicit activities.

KYC & AML Global Watchlists

What KYC & AML Global Watchlists should you refer to when compiling your datasets?

Know Your Customer (KYC) compliance requirements frequently require identity checks against known or suspected money laundering, terrorist, or other persons considered high risk. The following should be a start when compiling your datasets to check for your client KYC/AML program.

    • Bank of England Sanctions List (BOL)
    • Bureau of Industry & Security (BIS) Denied Persons List
    • Bureau of Industry & Security (BIS) Entity List
    • Bureau of Industry &Security (BIS) Unverified List
    • CIA World leaders
    • DFAT (Department of Foreign Affairs and Trade) List (Consolidated) Australia
    • Directorate of Defense Trade Controls (DDTC): Debarred Parties List
    • European Union : Consolidated List of Persons, Group, Entities
    • European Union: EU Terrorist List
    • FinCEN Section 311 – Primary ML Concern
    • European Union CFSP list (Common Foreign and Security Policy)– Entities subject to EU Sanctions
    • HM Treasury list UK
    • OFAC SDN (Office of Foreign Assets Control Specially Designated Nationals List)– USA
    • OFAC PLC – Palestinian Legislative Council List
    • OFAC Sanctions Programs
    • OSFI (Office of the Superintendent of Financial Institutions) list – Canada
    • OCC Office of the Comptroller of Currency: Unauthorized Bank List
    • UK Secretary of State Terrorist List:  Home Office
    • UN Consolidated List — United Nations
    • US General Services Admin (GSA): Excluded Parties List
    • System US Immigration and Customs Enforcement: ICE Fugitives
    • US State Dept. FTO Foreign Terrorist Organizations List
    • US State Dept. WMD Non-Proliferation List
    • World Bank List of Debarred Parties (Ineligible Firms & Individuals)

In another article I explained how at C6 Intelligence they base the definition of a PEP  (Politically Exposed Person) on the FATF version.

See: http://paulrenner.com/C6-Intelligence/C6-Intelligence-what-is-a-PEP-Politically-Exposed-Person-By-Paul-Renner-C6.html

Foreign PEPs are individuals who are or have been entrusted with prominent public functions by a foreign country, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.

Domestic PEPs are individuals who are or have been entrusted domestically with prominent public functions, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials.

Persons who are or have been entrusted with a prominent function by an international organisation  refers to members of senior management, i.e. directors, deputy directors and members of the board or equivalent functions.

The definition of PEPs is not intended to cover middle ranking or more junior individuals in the foregoing categories.

PEP Categorisation

For more in depth Regulatory Data and Insight lists see: http://www.c6-intelligence.com/Data/What_We_Cover

Paul Renner is the co-founder of C6 Intelligence Information Systems which is used daily by banks, financial institutions, insurance companies, and regulators to take a risk-based approach to managing fraud, money laundering and staff compliance risks.

Paul Renner is also the co-author of ”Preventing Financial Instrument Fraud – The Money Launderer’s Tool”, originally published by the ICC (International Chamber of Commerce) Commercial Crime Services(CCS), now called the ICC Financial Investigation Bureau. The fraud models described within the publication has been referenced by the UK City of London Police and prosecution services, to support their case and secure convictions against fraudsters.


14th Annual FIBA AML Compliance Conference – February 20-21, 2014 – Miami



Does your financial institution have a well-defined culture of compliance?

What does that even mean in terms of policies and procedures, controls, audit, hiring and training?
These are questions compliance personnel should consider in the current enforcement environment. Financial institutions are being subjected to heightened scrutiny as a result of the worst economic crisis that the world has suffered since the Great Depression:
  • J.P. Morgan Chase Bank recently agreed to pay a record-setting $2 billion to U.S. government agencies over claims that AML deficiencies caused the bank to fail to report suspicious activity involving longtime customer Bernard Madoff.
  • British banking giant HSBC agreed to a $1.9 billion settlement over AML matters.
  • TD Bank agreed to a total of $ 90 million in penalties related to Ponzi schemes by Florida attorney Scott Rothstein.

But how does a bank with a well-defined culture of compliance ensure that its employees are well trained to spot red flags and report any suspicions?

And how should those suspicions be escalated, documented and acted upon?

Does putting into place an enterprise-wide compliance structure necessarily equal a culture of compliance?

For banks that are serious about meeting their anti-money laundering requirements, these are questions that must be considered, and FIBA can help.

The upcoming 14th Annual FIBA AML Conference in Miami will offer sessions where compliance personnel can learn about the elements of a culture of compliance and put that information to work at their institutions.

With top industry experts and regulators on-hand to discuss trends and best practices, conference attendees have an opportunity to learn and network and prepare to protect their institutions.

Topics include:

What’s New in the AML Landscape Speakers from multiple financial industry participants share perspectives on emerging money laundering and terrorist financing topics and highlight what’s looming on the horizon.

Evolution in Financial Intelligence Units From their private sector beginnings in the late 1990s, banks’ FIUs have shifted from collecting and analyzing AML-related information to developing an environment of proactive financial intelligence relating to all financial crimes: money laundering, external and employee fraud, global sanctions, anti-corruption, even high risk customer due diligence. Panel will discuss this evolution and some current challenges, including cross-border information sharing and privacy issues across affiliates, and balancing often conflicting interests and expectations of law enforcement and regulators.

Corruption and Politically Exposed Persons Enhanced due diligence on PEPs has raised significant implementation issues. Are politically exposed persons always critically significant or has the industry’s approach shifted? What proportionate factors should determine a PEP’s significance and whether a PEP has access to launder corrupt funds?

How have multilateral and private sector financial institutions developed sustainable mechanisms to identify corruption and mitigate these risks?

Nexus of Cyber Fraud and Money Laundering What’s really taking place in anti-fraud and AML departments – parallel activities or joint collaboration? Cyber fraud has grown from intrusion and penetration of financial institutions to well organized, cross border financial crimes targeting banks’ and customers’ assets. What do financial institutions, security and compliance units need to know? How can they adapt to address these complex threats?

And much more…

For more details see : http://www.antimoneylaundering-fiba.com/pages/Agenda/

BBA Anti-Money Laundering Induction Workshop – Jan 24 2014

This induction workshop is an essential primer for all Officers assuming responsibilities for AML issues. The workshop explores and critiques the main concepts of the UK’s legal framework, POCA and reporting suspicions, Money Laundering Regulations, FCA requirements and industry guidance – key compliance obligations.

Date: 24/01/2014 

Venue: Pinners Hall, 105-108 Old Broad Street, London, EC2N 1EX

The workshop also covers a general introduction to sanctions regimes and screening, standards, compliance monitoring, and reporting to senior management, and has been fully revised and updated to reflect the Money Laundering Regulations 2007 and JMLSG Guidance notes and 3rd EU Directive, the requirement to follow a risk based approach.

Delegates will leave the workshop with a practical understanding of Fraud, Anti-Bribery & Corruption, Information Security, Market abuse & Insider dealing, and Sanctions; all critical components to AML.

Topics to be covered and objectives include:

    • Legal Obligations
    • Money Laundering Regulations 2007
    • JMLSG Guidance 2007
    • The Risk Based Approach
    • Managing the AML Process
    • New Dimensions in Financial Crime


Who should attend this workshop?

This workshop will be of particular interest to individuals working in the following areas:

    • Newly-appointed Financial Crime and Risk Management Officers
    • Newly-appointed MLROs and Deputies
    • Financial Regulation Managers
    • Internal Audit (assuming responsibilities for money laundering/financial crime issues)
    • Governance and Compliance Officers

Workshop Outline*:

Session I: The Current Legal & Regulatory Framework
Session II: Sanctions and counter-terrorism reporting
Session III: The MLRO Role in Practice
Session IV: Implementing a Risk-Based Due Diligence Regime
Session V: Managing an Effective Recognition and Reporting Regime
Session VI: Financial Crime – The Broader Perspective
Session VII: Workshop Summary and Q&A

Programme details:

Registration:  09:00
Start:  09:30
Close: 17:00
Lunch will be served and there will be two 15 minute breaks (mid-morning, mid-afternoon).

For more details:  http://www.bba.org.uk/events-and-training/event/anti-money-laundering-aml-induction-workshop