Anti-Money Laundering for VFA Issuers and Services Providers

Course Overview

The course consists of the following 9 topics, presently done through a 4-hour pre-recorded session:

1.     Money Laundering and Terrorist Financing – Brief overview

a.     Definitions

b.     The process of money laundering

c.     Legislative framework and recent developments

A general description of the VFA activities and services that are subject to regulation in terms of the Virtual Financial Assets Act and subject to AML/CFT obligations in terms of the PMLFTR.

2.     Vulnerabilities of VFA-Related Products and Services

a.     Specific risks associated with VFA-Related Products and Services

A consideration of the ML/FT risks such activities present in terms of ML/FT, especially why they are susceptible to being used for ML/FT (e.g.: the pseudo-anonymity of VFAs, the technologies that can further enhance the same, the rapidity of transactions, their borderless nature etc.), and the associated difficulties encountered by authorities to regulate, supervise and police this area.

Possible ML/FT red flags, trends and typologies.

3.     Concepts of Risk Management

a.     Concepts of risk assessment

b.     Identifying and assessing risk

4.     Implementing an AML/CFT Risk-based Approach

a.     The international standards and requirements

b.     Understanding risks

c.     Determining and applying a risk-based strategy and approach

d.     Continuous review of the risk-based approach to AML/CFT

Possible mitigating solutions that can be adopted to mitigate the said   risks,   including   best   practices   adopted   both locally and internationally and the analytical tools available to obtain information about particular wallet addresses etc.

5.     Customer Due Diligence (CDD)

a.     What is CDD

b.     Transparency and beneficial ownership requirements

c.     EDD and SDD

d.     High risk situations – PEPs & relationships with high-risk jurisdictions

e.     Third party reliance

6.     Escalation and Exit Strategies

a.     Escalation

b.     Exiting relationships

7.     The AML/CFT Governance Framework

a.     Managing AML/CFT compliance risks

b.     Defining roles and responsibilities

c.     The Money Laundering Reporting Officer (MLRO)

8.     Recognition, Handling and Reporting of Transactions

a.     The legal obligation to report

b.     Suspicious Transaction Reports

c.     The nominated officer’s evaluation process

9.     Post-reporting Considerations

a.     Handling the risk of committing the tipping-off offence

b.     Responding to discovery and enforcement orders

c.     Dealing with the Authorities


MIM Members: €125

Non-members: €150

For further information on the above, please contact us on: