Table of Contents

1. INRODUCTION AND BACKGROUND 3
2. CUSTOMER DUE DILIGENCE 4
3. IDENTIFICATION AND ESCALATION OF SUSPICIOUS TRANSACTIONS 6
3.1 FS policies and procedures 6
3.2 Training 6
3.3 Offences and penalties 6
4. CONCLUSION 7
5. BIBLIOGRAPHY 8
6. APPENDICES 9
6.1 Table of Acronyms 9
6.2 Presentation 9

1. INRODUCTION AND BACKGROUND

Money Laundering is the process of making “dirty money “or proceeds that have been acquired through illegal business to appear “clean” or legal. The proceeds or gains from this illegal business can be used to fund terrorism or drug business through the help of facilitators. During the 9/11 attacks on the twin towers in the United States, facilitators from UAE and Germany as well as Khalid Sheikh Mohammed (KSM) sponsored the attacks with an approximated amount of $500,000 (Roth, J et al., 2004) The report further states that out of this amount about $300,000 was transferred into the hijackers’ bank accounts in the United States which was used by them for flight training, living expenses and transport.
Bank should have appropriate risk-based procedures to determine whether a customer or a beneficial owner is PEP (IFIA, 2013, p. 19). Depending on the risk profile of the customer, a bank should decide if the customer requires a simplified due diligence, which involves less verification, scrutiny of the client before onboarding into the bank. If the customer falls under high risk category, than bank should perform additional scrutiny of the customer’s transactions and background through enhanced due diligence activity, which results in extra time and cost to the