AML & Sanctions Compliance in Trade Finance Program

Programme description & objectives

Majority of the banks and regulatory organizations who have failed to put adequate Anti Money Laundering (AML) and sanctions compliance programs and training in place have incurred penal fines, reputational damage and faced the potential loss or suspension of their ability to operate in certain currency markets or jurisdictions. This workshop is therefore focused on the associated AML and sanctions compliance risks in Trade Finance. The course is geared to, and has been designed for correspondent bankers, trade operational and sales personnel and compliance officers to enable them to identify compliance risk zones in each of these product areas. The course uses a range of typologies, exercises and case studies to develop the understanding of delegates in a practical and engaging way across a range of scenarios. Delegates to the program will understand the function, parties, role, operation, compliance risks & red flags of: - Fundamental role of correspondent banking in international trade flows - High compliance risk characteristics and vulnerabilities - Trade finance products (LCs, collections, bank aval) - Guarantees, standby LCs, transferable guarantees - Pre-export finance - Trade receivables purchase finance - SWIFT messages

Venues, Dates & Cost

VenuesDubaiDublinEdmontonGhanaLondonNigeria
DatesTBDTBDTBDTBDTBDTBD
Cost$4,000 per participant (USD) (=N=)

For Whom

  • Compliance Officers, Team Leaders, and Managers
  • Regulators of Foreign Exchange Markets and Operations
  • Financial Crime & Fraud Prevention Employees
  • Trade Operational and Sales Personnel

Module 1: Introduction to Compliance Risk

  • Compliance Risk in Cross-Border Transactions
    • Nature of compliance risk
    • Why cross-border transactions are abused
  • Anti-Money Laundering (AML)
    • Risk-based approach
    • Stages: placement, layering, integration
    • Suspicious transactions
  • Sanctions Violations
    • Nature, purpose, impact
    • Trade embargo & financial sanctions
    • Currency implications & USD transfer exposure
    • Bank risk & cost of non-compliance
    • Case study: AML & sanctions violation
  • Correspondent Banking
    • Function, parties, role in trade flows
    • Gateway to compliance risk
    • Infrastructure & message authentication
    • Nostro/vostro accounts
    • Compliance risk areas & market trends
    • Exercise: Due diligence and risk considerations
  • SWIFT Compliance Risk
    • Message abuse, omission, stripping
    • Originator/beneficiary checks
    • Screening sanctioned persons/countries
  • Trade-Based Money Laundering (TBML)
    • Methods & typologies
    • Misrepresentation in price/goods
    • Multiple invoicing
  • Documentary Collection
    • Operation, parties, types (DP, DA, Aval)
    • Compliance risk profile
    • Case study: Avalised bill of exchange
  • Letters of Credit (LCs)
    • Operation, parties, trade documentation
    • Sanctions clausing
    • Fragmented bank roles & exposure
    • LC confirmation
    • Case study: Money laundering LC transaction
    • Compliance risk assessment by bank role
    • Case study: Unusual LC features & red flags

Module 2: Advanced Trade Finance Compliance

  • Transferable Letters of Credit
    • Operation, parties, transfer changes
    • Product compliance risk profile
    • Case study: Suspicious transferable LC
  • Synthetic Letters of Credit
    • Operation, parties
    • Compliance risk profile
    • Case study: Synthetic LC transaction
  • Standby Letters of Credit
    • Operation, parties, claim documentation
    • Money laundering misuse
    • Compliance risk profile
    • Case study: Suspicious standby LC claim
  • Trade-Related Guarantees
    • Unconditional on-demand guarantees
    • Key aspects & types
    • Advance payment guarantees
    • Transferable guarantees & URDG 758
    • Case study: Transferable guarantee risk assessment

Module 3: Receivables & Structured Trade Finance

  • Receivables Finance
    • Parties & compliance risk in open account
    • Forms: debt purchase, factoring
    • Case study: Due diligence in invoice purchase
  • Structured Trade & Commodity Finance
    • Introduction, function, operation
    • Compliance risk zones
  • Pre-Export Finance
    • Operation, parties, due diligence
    • Typology: commodity-based pre-payment misuse
    • Case study: Commodity-based finance risk