A programme that is designed to support risk and compliance professionals to identify and report suspicious customer behaviour and transactions according to legal requirements.
Course Structure
Why SARS are important.
Think like a criminal – aims and objectives.
Crime trends and typologies.
Legal and Regulatory responsibility under POCA and TA.
All regulated sector employees who contribute to the process of customer risk assessment
CDD/KYC analysts
SAR investigators
Senior FC professionals including MLRO and DMLRO
Internal Auditors
Compliance Monitoring and Assurance
Learning Outcomes
By the end of this programme, you will be able to:
Outline why SARS are important.
Confidently distinguish between changes in customer activity or behaviour that is usual and activity that is unusual activity that may indicate crime or the finance of terrorism.
Outline the personal responsibilities as defined under the Proceeds of Crime Act 2002 (as amended) and Terrorism Act 2000 to report suspicious activity and avoid the risks of tipping off and prejudicing an investigation.
Explain when and how to make a report of unusual activity according to company internal policies and procedures.
Describe the information that is required to be included when making a report of unusual activity.
Explain the ‘consent’ requirements of reporting in the UK and obtaining a defence against money laundering.
Manage the risks after a SAR is made.
Topics Covered
What will I learn?
SARS in Action.
POCA 2002.
Terrorism Act 2000.
Economic Crime and Corporate Transparency Act 2023.
The National Crime Agency.
USA BSA FinCEN Filings.
Unusual activity – disguised identity, ownership and control of illicit value or activity:
Shell companies and front companies.
Formal and informal nominees, including Trust and Corporate Service Providers.
Identity fraud techniques.
Muling and smurfing.
Unusually complex layering.
Reporting unusual activity and ‘red flags’
Reporting under the POCA and TA.
Delivery Formats
Delivered though our online learning management system (LMS) accompanied by recorded instructor-led training