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Anti-Money Laundering (AML)/Combating Financing Of Terrorism (CFT)

Money laundering involves taking criminal proceeds and disguising their illegal source in anticipation of ultimately using these proceeds to carry out legal and illegal activities. Stated another way, money laundering is the process of making dirty money look clean. Money laundering often involves a complex series of transactions that are usually difficult to separate. There are three phases of money laundering: placement, layering and integration. Financial institutions are required by law to undertake customer due diligence (CDD) when establishing relationships, carrying out occasional transactions, there is suspicion of money laundering (or terrorist financing) or the financial institution has doubt about the veracity or adequacy or previously obtained customer identification data.

Terrorist financing, on the other hand, involves the advancing of financial support, in any form, to terrorists or to those who encourage, plan or engage in terrorist act. While funding for money laundering is derived from only illicit sources, terrorist financing comes from both legitimate and illegitimate sources.  The September 11, 2001 terror attacks on the World Trade Centre and Pentagon changed the global approach to combating terrorist financing. For money laundering, the purpose of laundering is to enable the fund to be used legally. The fact that terrorist funds often comes from legal sources raises an important legal problem as far as applying anti-money measures to terrorist financing. LeishTon can work with you to develop robust and tailored AML/CFT and Know-your-Customer (KYC) policies, manuals and standards to enable you deliver on your AML/CFT mandate, including CDD, EDD and the rendition of relevant threshold and suspicious transactions reports. We also have the expertise to review your AML/CFT activities and the AML function. Key compliance documentation LeishTon can work with you to deliver include:

  AML/CFT Policy
AML/CFT Manual
KYC Manual
Risk-Based AML/CFT Programme