Money laundering through money remittance ... - Council of Europe

2010 - Money Laundering through Money Remittance and Currency Exchange Providers
Customers who offer different identifications or identifiers on different occasions;
Customers who receive transactions in a pattern consistent with criminal proceeds; and
Customers who receive transfers in seasonal patterns consistent with criminal proceeds.
110. Regarding transactions conducted by MR/CE businesses, it is essential that there be control
mechanisms that will permit the identification of any money flows or customers warranting closer
scrutiny. This should also apply in cases of single-person businesses. In larger MR/CE businesses, the
person responsible for compliance with AML/CFT measures should ensure that internal monitoring
processes provide for effective controls and readily available information concerning, inter alia:
Who approaches as a customer, how often, when, from where, remitting or receiving how
much, and the probable and plausible rationale for that;
Many customers sending to one beneficiary;
One customer sending to several beneficiaries (and other similar schemes);
The use of data and IT to scan for patterns of transactions.
111. There are a number of other areas which should be considered carefully by the MR/CE
service providers. For example, the background of the employees should be carefully checked. Also,
at the company level, it is important that employees regularly receive appropriate training on
AML/CFT measures. Such training should ensure not only that they understand their responsibilities
but also have sufficient knowledge to detect any suspicious activity. For this purpose, written
compliance procedures are of paramount importance. Also, other issues include the need to prevent
situations when data/ input by operators could be insufficient, incorrect or subsequently modified
fraudulently without any possibility to track subsequent changes, which would impact on the
usefulness or accuracy of the information kept by the MR/CE service providers.
5.2 Additional measures to be considered at national and international level
112. Knowledge of the sector, services offered and transaction channels: There is clearly a need
for competent authorities to understand fully how the sector operates and the services it provides, as
well as developments in the sector, which could be exploited for ML/TF purposes. In order to further
solidify understanding of the MR/CE sector along with its vulnerabilities, regulators should therefore
engage in a continuing dialogue with MR/CE providers. Such a dialogue would also make them more
aware of the measures that some service providers themselves already take to oversee the activity of
their agents as far as compliance with AML/CFT measures.
113. Awareness raising – Outreach to the MR/CE sector, generally, to explain and reinforce
AML/CFT obligations, as well as to enhance industry supervision, is important. Making the general
public more aware of the need for AML/CFT measures to be applied to MR/CE services can be
equally important however. Such awareness raising may assist in building trust in the regulated
system and thus help to foster the use of the system rather than underground or unauthorised means for
the movement of funds.
114. Guidance and training – Since many MR/CE service providers tend to lack the capacity,
experience and resources to implement AML/CFT requirements, regulators and/or supervisors have a
key role to play in this process by providing adequate guidance to the sector. Given the specific nature
MR/CE activity where adequate knowledge of the customer is heavily reliant on effective
42 - © 2010 MONEYVAL and FATF/OECD