Mauritius NEW AML 2020 handbook - It is time to start planning your 2020 AML training

Have you seen the Mauritius FSC has published its NEW AML handbook

• https://www.fscmauritius.org/media/82215/fsc-aml-cft-handbook-13012020-for-website.pdf -

Some key facts are as follows:-

• The Financial Services Commission (FSC) has issued its NEW Anti-Money Laundering and Countering the Financing of Terrorism Handbook. (the ‘Handbook’) - https://bit.ly/2Tns3gj
• This ‘Handbook’ consolidates the Financial Services Commission (the ‘FSC’) guidance on anti-money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction.
• A failure to comply with the handbook will result in regulatory action and depending on the severity of the breach; it may result in revocation of a licence of a business. Actions under the Administrative Penalties
• Regulatory Framework (approved by the Board of the FSC on 24 July 2019 and issued on 19 August 2019) may also apply as appropriate.
• The FSC will take this Handbook into account when assessing the level of compliance with the FIAMLA, FIAML Regulations 2018 and the Code while conducting its onsite visits.

TRAINING

In taking account of the above, I have outlined below the NEW AML handbook training requirements. In reading through these requirements and as many Mauritian firms know Comsure has been meeting these parameters for the last 15 years. And Comsure is coming back in 2020.

If you are interested in up to date and cutting edge (& fun) AML training that meets all the requirements below please contact me. Remember every year Comsure has more interest than capacity, so to avoid disappointment do not delay in contacting me and booking your workshops.

On training the NEW AML handbook says……

In providing the training required, pursuant to Regulation 22(1)(c) of FIAML Regulations 2018 and this Handbook, the financial institution must:

a) provide appropriate training to directors, officers and employees to enable them to competently analyse information and documentation, so as to enable them to form an opinion on whether the transactions and actions may be linked to money laundering or terrorism financing;

b) detail procedures that need to be followed if any links to money laundering or terrorism financing have been identified;

c) prepare and provide to employees a copy, in any format,

1. of the financial institution’s policies, procedures and controls manual for AML and CFT; and
2. FSC AML/CFT Handbook

d) ensure employees are fully aware of all applicable legislative requirements.

In accordance with Regulation 22(1)(c) of FIAML Regulations 2018, the ongoing training provided by the financial institution shall cover:

a) the FIAMLA, FIAML Regulations 2018, any AML/CFT Code issued by the FSC and this Handbook;

b) the implications of non-compliance by employees to requirements of FIAMLA, FIAML Regulations 2018, any AML/CFT Code issued by the FSC and this Handbook;

and

c) the financial institution’s policies, procedures and controls for the purposes of foreseeing, preventing and detecting ML and TF.

The financial institution must ensure that the ongoing training provided to directors, officers and employees also covers, to a minimum:

a) the requirements for the internal and external disclosing of suspicion

b) the criminal and regulatory sanctions in place, both in respect of the liability of the financial institution and personal liability for individuals, for failing to report information in accordance with the policies, procedures and controls of the financial institution;

c) the identity and responsibilities of the MLRO, CO and Deputy MLRO;

d) dealing with business relationships or occasional transactions subject to an internal disclosure, including managing the risk of tipping off and handling questions from customers;

e) those aspects of the financial institution’s business deemed to pose the greatest ML and TF risks, together with the principal vulnerabilities of the products and services offered by the financial institution, including any new products, services or delivery channels and any technological developments;

f) new developments in ML and TF, including information on current techniques, methods, trends and typologies;

g) the financial institution’s policies, procedures and controls surrounding risk and risk awareness, particularly in relation to the application of CDD measures and the management of high risk and existing business relationships;

h) the identification and examination of unusual transactions or activity outside of that expected for a customer;

i) the nature of terrorism funding and terrorist activity in order that employees are alert to transactions or activity that might be terrorist-related;

j) the vulnerabilities of the financial institution to financial misuse by PEPs, including the effective identification of PEPs and the understanding, assessing and handling of the potential risks associated with PEPs; and

k) UN, EU and other sanctions and the financial institution’s controls to identify and handle natural persons, legal persons and other entities subject to sanction.

The list included above is non-exhaustive, and there may be other areas the financial institution may deem appropriate to include, based on the business of the financial institution and the conclusions of its business risk assessments.

Close

• Comsure is coming back in 2020.
• If you are interested in up to date and cutting edge AML training that meets all the requirements below please contact me. Remember every year Comsure has more interest than capacity, so to avoid disappointment do not delay in contacting me.

Mathew Beale - Chartered FCSI

Principal (Director) - Comsure Compliance Limited, Comsure Technology Limited, Comsure Group Limited (the “Comsure Group of Companies”)

No 1 Bond Street Chambers, St Helier, Jersey, Channel Islands, JE2 3NP

Direct Tel: +44 (0) 1534 626841 - Mobile Tel: +44 (0) 7797 747 490

Skype: comsurecompliance

mathewbeale@comsuregroup.com

www.comsuregroup.com