Natural Resources and Violent Conflict - WaterWiki.net

follow the money 187to establish the identity of its clients and beneficial owners beforeaccepting money; (b) demanding adequate identification before openingan account; (c) determining the source of wealth, the person’s networth, and the source of the person’s funds; and (d) requiring two persons,rather than just one, to approve the opening of an account• Engage in additional diligence or attention in cases involving theuse of numbered or alternative-name accounts, high-risk countries,offshore jurisdictions, high-risk activities, or public officials• Updateclientfileswhentherearemajorchangesincontroloridentity• Identify unusual or suspicious transactions, follow them up, andthen decide whether to continue the business relationship with heightenedmonitoring, end the relationship, or advise authorities• Monitor accounts through some means• Develop and implement a “control policy” to ensure compliancewith bank rules• Establish a regular method of reporting on money launderingissues to management• Train bank employees involved in private banking on the preventionof money laundering• Require the retention of bank records that might be material toanti–money laundering matters for at least five years• Establish an “exception and deviation procedure that requiresrisk assessment and approval by an independent unit” for exceptionsto the previous nine principles• Establish an anti–money laundering unit at the financialinstitution. 28The signatories to the Wolfsberg principles did not create a mutualassessment or other evaluative mechanism, relying instead on anhonor system whereby reputational injury was considered an adequatedisincentive to any failure by a member to meet its public commitments.In just two years, the Wolfsberg Group has extended its originalmandate twice. In January 2002 it issued a set of principles on thesuppression of the financing of terrorism, and in September 2002 it issueda set of principles for correspondent banking, which has been oneof the areas of greatest vulnerability to money laundering for moneycenter banks. Major elements of the Wolfsberg principles for antiterrorisminclude the following:• Require strict adherence to “know your customer” policies by requiringthe proper identification of customers by financial institutionsand the matching of such identifications against lists of known or suspectedterrorists issued by competent authorities having jurisdictionover the relevant financial institution. This principle further includes