IMPLEMENTATION STRUCTURE & EXPECTED OUTCOMES FOR

Transcript:IMPLEMENTATION STRUCTURE & EXPECTED OUTCOMES FOR:
IMPLEMENTATION STRUCTURE & EXPECTED OUTCOMES FOR RECOMMENDATION 16, 17, 18, 19 & 20 Oladele Adeoye OUTLINE Introduction Recommendation 16 Recommendation 17 Recommendation 18 Recommendation 19 Recommendation 20 Conclusion INTRODUCTION Structure 16 17,18&19 20 RECOMMENDATION 16 Wire Transfer (Regulation 23) RECOMMENDATION OBJECTIVES Prevent Terrorist & Criminals from moving funds Detecting movement of illicit funds Ensuring that basic information about originators & beneficiaries of funds are immediately available to LEAs, FIU Complying with freezing action and prohibition of dealings with designated persons and entities. RESPONSIBILITIES OF PARTIES TO WIRE TRANSFER The Parties Ordering financial institution Intermediary Financial Institution Beneficiary Financial Institution Capture both originator & beneficiary information Transaction below reputable threshold should be captured Keep records Do not deal without information Keep records of parties to wire transfer The records of all transfer should be kept for 5yrs Have a RB mechanism for execute, reject or suspend deal without proper information Put in place enhanced real time or post event monitory in place on transaction lacking details Identify and verify beneficiaries Have a RB mechanism for execute, reject or suspend deal without proper information RECOMMENDATION SCOPE SCOPE Domestic wire transfer Qualifying cross border wire transfer DOMESTIC WIRE TRANSFER Capture originator information Account number Transaction reference number Information should be made available on request or within a maximum period of (3) working days to: Beneficiary financial institutions Statutory bodies LEAs QUALIFYING CROSS BORDER WIRE TRANSFER Capture name of the originator Capture account number if used to process transaction Capture identification details Capture name of beneficiary Capture account number of beneficiary if used LIMITATION TO WIRE TRANSFER Purchases transaction involving debit/credit/prepaid card accompanied by card numbers Financial institution to financial institutions REGULATORY FRAMEWORK (REG. 23) Get originator info File STR to NFIU where info is not available Restrict/terminate relationship with originator financial institution that fail to meet standard RECOMMENDATION 17 Reliance on third party Regulation 28 RELIANCE BASIS Identification & verification of customer using reliable, independent source document Identification and verification of beneficial owners. Understanding purpose and intending nature of business relationship RELIANCE CRITERIA Obtain information relating to customer immediately from the third party Take steps to be satisfied that copies of identification data and other relevant documentation relating to CDD are readily available Be satisfied that the third party is regulated, supervised or monitored for CDD and record keeping Be satisfied that the third party has measures for CDD and record keeping Give