Account monitoring order
____ _____ ____ : In the United Kingdom and several other countries, an order from a government authority requiring a financial institution to provide transaction information on a suspect account for a specified time period.
_____ : A written statement given under oath before an officer of the court, notary public, or other authorized person. It is commonly used as the factual basis for an application for a search, arrest or seizure warrant.
Alternative Remittance System
___ ____ ____ : Underground banking or informal value transfer systems. Often associated with ethnic groups from the Middle East, Africa or Asia, and commonly involves the transfer of values among countries outside of the formal banking system. The remittance entity can be an ordinary shop selling goods that has an arrangement with a correspondent business in another country. There is usually no physical movement of currency and a lack of formality with regard to verification and record- keeping. The money transfer takes place by coded information that is passed through chits, couriers, letters or faxes, followed by telephone confirmations. Almost any document that carries an identifiable number can be used by the receiver to pick up the values in the other country. The systems are referred to by different names depending upon the country: Hawala (an Arabic word meaning "change" or "transform"), Hundi (a Hindi word meaning "collect"), Chiti banking (referring to the way the system operates), Chop Shop banking (China), and Poey Kuan (Thailand).
Anti-Money Laundering International Database
____-____ ____ ____ ____ : A compendium of analyses of anti-money laundering laws and regulations, including two general classes of money laundering control measures—domestic laws and international cooperation—as well as information on national contacts and authorities. A secure, multilingual database, AMLID is an important reference tool for law enforcement officers involved in cross-jurisdictional work. (See www.imolin.org/amlid/index.html.)
Anti-Money Laundering Program
____-____ ____ ____ : The system designed to assist institutions in their fight against money laundering and terrorist financing. In many jurisdictions, government regulations require financial institutions, including banks, securities dealers and money services businesses, to establish such programs. At a minimum, the anti-money laundering program should include: 1. Written internal policies, procedures and controls; 2. A designated AML compliance officer; 3. On-going employee training; and 4. Independent review to test the program.
Anti-Money Laundering Program and Counter Financing of Terrorism Program
See Anti Money Laundering Program
____ ____: A court order directing a law enforcement officer to seize and detain a particular person and require them to provide an answer to a complaint or otherwise appear in court.
Asia/Pacific Group on Money Laundering APG
____ /____ ____: A Financial Action Task Force (FATF)-style regional body consisting of jurisdictions in the Asia/Pacific Region. See www.apgml.org.
____ _____: A person appointed through a written contract by a company or trust to direct the entity's investment program. The program can be a fully discretionary account, or the contract can impose limitations on it. Fees to the ____ ____ can be based on performance achieved, trading commissions or a percentage of the valuation of the estate under his or her management. High fees and a close relationship with the owners or beneficiaries can expose the ____ ____ to potential conflicts between a duty to report unusual or suspicious activity and the fiduciary duty to the client.
____ ____: A process that includes reorganizing how assets are held so as to make them less vulnerable should a claim be made against a person. ____is also a term used by tax planners for measures taken to protect assets from taxation in other jurisdictions.
Asset Protection Trusts
____ ____ ____ : A special form of irrevocable trust usually created (i.e., settled) offshore for the principal purposes of preserving and protecting part of one's wealth from creditors. Title to the asset is transferred to a person named the trustee. ____s are generally used for asset protection and are usually tax neutral. Their ultimate function is to provide for the beneficiaries. Some proponents advertise ____s as allowing foreign trustees to ignore U.S. court orders and to simply transfer the trust to another jurisdiction in response to legal action threatening the trust's assets (so-called " ying trusts").
Automated Clearing House
____ ____ ____: An electronic banking network that processes large volumes of both credit and debit transactions that originate in batches. ____ credit transfers include direct deposit payroll payments and payments to contractors and vendors. ____ debit transfers include consumer payments on insurance premiums, mortgage loans and other kinds of expenses. The system is used for bulk orders made days in advance—for example, a large corporation's entire payroll. Both governments and commercial sectors can use the ____ system. The ____ system was designed to transfer a high volume of low-dollar domestic transactions, which pose lower money laundering risks. Nevertheless, the ability to send high-dollar and international transactions through the ____ may expose financial institutions to higher money laundering risks. Firms without a robust AML monitoring system may be exposed to additional risk, particularly when accounts are opened over the Internet without face-to-face contact.
Automated Teller Machine
An electronic banking outlet that allows customers to complete basic transactions without the assistance of a bank employee. ATMs generally dispense cash, allow check and cash deposits and transfers to be made, as well as balance inquiries
___ ___: Vulnerable to money laundering because it represents a reputable international monetary instrument drawn on a reputable institution, and is often made payable—in cash— upon presentation and at the issuing institution's account in another country.
Bank for International Settlements
____ ___ ____ ____: An international organization that serves as a bank for central banks and which fosters international monetary and financial cooperation with the purpose of attaining stability in the world economy. It hosts the Secretariat of the Basel Committee on Banking Supervision. The Committee has formulated broad supervisory standards and guidelines on Know Your Customer issues. See www.bis.org.
___ ___ ___: Refers to laws and regulations in countries that prohibit banks from disclosing information about an account—or even revealing its existence—without the consent of the account holder. Impedes the ow of information across national borders among financial institutions and their supervisors. One of FATF's 40 Recommendations states that countries should ensure that secrecy laws do not inhibit the implementation of the FATF Recommendations.
Bank Secrecy Act
___ ___ ___ : The primary U.S. anti-money laundering regulatory statute (Title 31, U.S. Code Sections 5311-5355) enacted in 1970 and most notably amended by the USA Patriot Act in 2001. Among other measures, it imposes money laundering controls on financial institutions and many other businesses, including the requirement to report and to keep records of various financial transactions.
Bank Secrecy Act Compliance Program
___ ___ ___ ___ ____ : A program that U.S.-based financial institutions—as defined by the Bank Secrecy Act—are required to establish and implement in order to control money laundering and related financial crimes. The program's components include at a minimum: the development of internal policies, procedures and controls; the designation of a compliance officer; ongoing employee training; and an independent audit function to test the program.
____ ____: Also known as a dry, formal, naked, passive, or simple trust, in which the trustees have no duties other than to convey the trust property to beneficiaries when called upon to do so. ___ ____s are vulnerable to money laundering because the final beneficiary is unknown.
Basel CDD Paper
____ ___ ____: A guidance paper on Customer Due Diligence (CDD) for banks issued by the Basel Committee on Banking Supervision (BCBS) in October 2001. The paper includes sound Know Your Customer policies and procedures that, according to the Committee, are critical to protecting the safety and soundness of banks and the integrity of banking systems. In February 2003, the Basel Committee on Banking Supervision issued "General Guide to Account Opening and Customer Identification." This document is an attachment to the Basel CDD Paper. See www.bis.org/bcbs.
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