Effectiveness Review Presenter: Shauna MacKenzie Director, Legal Services & Enforcement Bermuda...
Transcript of Effectiveness Review Presenter: Shauna MacKenzie Director, Legal Services & Enforcement Bermuda...
Effectiveness ReviewPresenter: Shauna MacKenzie Director, Legal Services & EnforcementBermuda Monetary Authority
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Institution’s Due Diligence
Customer Due DiligenceAnnual Independent audit
Compliance OfficersQualifications/fitness and proprietyNotify the BMA of changes
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Operations of Regulator
Operations of RegulatorMore AML examinations
Onsites - more identification of risks - Offsites with profile and
statistics
Domestic Cooperation and Communications – FIA/ BPS
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Training
1. More SAR’s – more attention to high networth investors
2. CDD Quality of copies
- consistent list of documents for recordsID verification – need to procure documents to verify wealthGuidance for ultimate beneficial ownerGreater sensitivity to layering practicesClear updating on PEP’sEquivalent Countries
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3. Smaller entities – ongoing monitoring of transactions
How to apply risk based in P & P’s 0 need to delve more into international risk assessment work on other countries – ICRG
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Any queries?