• overall risk (in percents) — the possibility that the address is related to illegal activities,
• sources of risk — known types of services with which the address has interacted and for which the total risk is calculated.
In AMLBot you can check BTC, ETH, LTC, BCH, Tether OMNI, XRP and 1500+ ERC-20 tokens (including Tether, BNB, QC, NEXO, TUSD, and 60+ DeFi tokens).
Anti Money Laundering Program is a set of rules and procedures that financial institutions must follow in order to prevent and timely detect money laundering or terrorist financing activities.
Generally, the development of an AML program is the responsibility of the top management of the company. For this, a set of rules and procedures are created, necessarily taking into account the needs and characteristics of the company (what products and services it provides, where it is located geographically, and who are the customers). As part of the AML program development, a senior specialist should be appointed who will be responsible for the overall implementation of the AML policy in the organization.
An effective AML compliance program for banks includes the following items:
• risk-based approach
• verification of a client’s identity (full name, date, and place of birth, the type of business the customer represents as an owner or an employee)
• check of the client’s belonging to politically exposed persons
• check for inclusion in international sanctions lists
• monitoring clients’ transactions to detect suspicious activity
• submission of reports on the detected suspicious activity to financial authorities
• AML training courses for bank employees and the creation of a separate position of an AML Compliance Officer.
AML’s risk-based approach means that the AML compliance program must be tailored to the individual levels of risk exposure that each client presents. This approach proved to be much more effective than the outdated one when a standardized list of AML compliance requirements was executed for each client. The risk-based approach shifts the focus from the analysis of events that have already occurred to the pre-emptive assessment of the collected data.
Each client must be assessed individually. In addition to going through the KYC (“know your client”) procedure, they must be checked for inclusion in sanctions lists, the lists of politically exposed persons, and the presence of negative news about them in media.
Monitoring must be continuous. This means you cannot verify an identity once and rely on that data forever, as customer risk profiles can change over time.
Whether you are interested in the position of a Compliance Officer or want to organize AML training courses for your staff, there are many options. Turn your attention to seminars, lectures, conferences, and round tables dedicated to AML/СFT topics. You can read the report of an international consulting company or the FATF Plenary meeting. But the best way to learn everything about AML is to study and obtain an international certification at ACAMS (Association of Certified Anti-Money Laundering Specialists). Keep in mind that training in the field of compliance and anti-money laundering never ends, and you will need to keep abreast of the new FATF regulations, laws of different countries, and AML software solutions.
For an Anti Money Laundering Compliance Program to operate at full capacity and help an organization analyze and detect potential risks, the four key components must be ensured.
1. The presence of the position of an AML Compliance Officer. Such an employee must have sufficient experience and broad powers in the company. Among other things, their responsibilities will include communication with the authorities, auditors, and the organization’s management.
2. Individual internal policies and means of control. The program should include regular reviews of these controls to ensure that they are effective. Staff should be aware of their roles and responsibilities in this system. Internal policies should be individually adapted based on a written assessment of the risks associated with the business.
3. Continuous training of employees in the principles of compliance with AML standards. In doing so, it is important to keep accurate records of all training provided and those who completed training.
4. Conducting independent external audits by a qualified third-party company. Such audits should be carried out at least once a year, and more often in high-risk areas. The purpose of the audit is to confirm that the AML program is working as intended and that the means of internal control are effective.
At the legislative level, the AML programs of any organization are based on the four main documents.
1. FATF recommendations. The Financial Action Task Force on Money Laundering (FATF), an intergovernmental organization, has issued 40 AML recommendations, which are reviewed approximately every five years.
2. 4AMLD and 5AMLD. 4th and 5th European Union Anti-Money Laundering Directives to be complied with by all EU member states.
3. Advisory document of the UK Financial Conduct Authority (FCA) intended for individuals, firms, exchanges that have any relation to cryptocurrencies.
4. The US Bank Secrecy Act (BSA).
To develop an AML program, an organization needs to define and outline an individual set of standards for combating money laundering. This task should be performed by specialized staff with resources, including appropriate technology, training materials, and legal advice.
When designing an AML compliance program, consider the following:
– international and local anti-money laundering legislation;
– fines for non-compliance with AML norms;
– definition of standardized forms for collecting exhaustive information about clients;
– recommendations for internal confidentiality and security;
– different levels of employees in the organization with appropriate access to information;
– the procedure for storing and deleting information;
– the percentage of risk to which a given industry is exposed (high-risk products and services AML);
– risk mitigation policy, KYC, and the identification of high-risk clients;
– suspicious activities that should be brought to the attention;
– markers and indicators of money laundering;
– the process of reporting suspicious activity to the authorities;
– the appointment of an AML Compliance Officer (or Anti Money Laundering Consultant).
To avoid cryptocurrency AML risk and check a transaction or wallet for AML compliance, you need to know a specific address and have a special analytical tool (AML compliance software).
One example of AML transaction monitoring software is AMLBot. With its help, a legal entity can carry out automatic crypto monitoring on its service using API. An individual can check transactions manually via Telegram or on the web service of the AMLBot website.
The concept of AML verification can be considered on the example of a cryptocurrency exchange. When registering on the exchange, the user will be asked to provide documents confirming his identity. Most commonly, two documents will be necessary: a passport or driver’s license and a document that confirms the user’s residence address. The exchange must be sure that the user does not impersonate somebody else. The AML verification procedure can take up to two weeks, according to crypto trading risk management policies. If a user of a cryptocurrency exchange has delayed submitting documents, they may be denied registration. And if they submitted inaccurate information, they will be included in the list of suspicious persons and an investigation for fraudulent activities will be initiated.