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Ethics of Money Laundering Regulations

Anti-Money Laundering Training Course

Table of Contents

Section 1 — What is Money Laundering?

  • Section 1956 of Title 18
  • Specified Unlawful Activity

Section 2 — How Money is Laundered

  • Placement
  • Layering
  • Integration

Section 3 — Suspicious Activity and Terrorist Financing

  • Signs of Money Laundering
  • Types of Behavior
  • Filing an SAR
  • Transactions Requiring Filing an SAR

Section 4 — Regulatory and Enforcement Framework against Money Laundering

  • Bank Secrecy Act of 1970
  • Reports/Registrations Required by the Bank Secrecy Act of 1970

Section 5 — NFA Compliance Rule 2-9

  • Anti-Money Laundering Program Minimum Requirements
  • Interpretive Notice #9045
    • Steps
    • Procedures
      • Knowing your Customer

Section 6 — Recognizing and Reporting “Suspicious Activity”

  • Hiring Qualified Staff
  • Record Keeping

Section 7

  • Designation of a Compliance Officer
  • Employee Training Program
  • Independent Audit Function
  • Sanctions for Money Laundering
    • Violations of Section 1956(a)(1) and 1956(a)(2)
      • Structuring Violations

Section 8

  • Asset Forfeiture
  • Burden of Proof
  • Court-Appointed Legal Representation
  • “Innocent Owner” Defense
  • Substantial Hardship
  • Payment for Damage to Improperly Seized Property
  • Fitting the Punishment to the Crime
  • Real Estate Forfeiture
  • Use of Criminal Forfeiture
  • Use of Civil Forfeiture

Section 9

  • Penalties for Failure to Report as Required
  • Suspicious Activity Report (Form SAR)
  • Currency Transaction Report (Form CTR)
  • Report of International Transportation of Currency or Monetary Instruments (CMIR, Form 4790)
  • Foreign Bank and Financial Accounts Report (FBAR, Form TD F 90-22.1)

Section 10

  • Report of Cash Received in a Trade or Business (Form 8300)
  • Reports Pursuant to Geographic Targeting Orders
  • Registration as a Money Services Business (Form TD F 90-22.55)

Conclusion

  • Long-Term Consequences of U.S. Money Laundering Legislation
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