WHY DO MONEY REMITTERS HAVE AML/CTF OBLIGATIONS?
WHAT SERVICES ARE COVERED BY AML/CTF OBLIGATIONS?
WHAT ARE THE ML/TF RISKS FACED BY MONEY REMITTERS?
WHAT IS A RISK BASED AML/CTF REGIME?
HOW CAN CUSTOS ADVISORY HELP?
The money remittance industry is extremely diverse, ranging from large international companies with outlets worldwide to small, independent convenience stores in communities with population concentrations that do not necessarily have access to traditional banking services.
The range of products and services offered, and the customer bases served, are equally diverse.
The definition of money remitter is wide, but the types of businesses are quite distinct. Some offer a variety of services, whilst others only offer money services as an ancillary component to their primary business.
The Money Laundering and Terrorist Financing (ML/TF) risks associated with the money remittance sector include:
Due to the number of transactions and intermediaries each transaction does not always have a single coherent set of documentation which identifies the remittance chain
Remittance businesses may receive instructions over the phone or by other non-face to face means, so they may not always know for whom they are acting
The use of intermediaries and the possible consolidation of remittances into one sum means that money is coming in from many sources and no one person or organisation may have responsibility for knowing the identity of all the sources
Businesses within the money remittance sector captured by the AML/CTF obligations must ensure the organisation conducts a comprehensive ML/TF risk assessment to identify, assess, mitigate and manage ML/TF risk exposures. This is a critical first step in complying with AML/CTF laws.
These are the services offered by money remitters included as designated services under the AML/CTF Act.
Transferring money or value for, or on behalf of, a customer
Trading for the accounts of customers in foreign exchange
Money or currency changing
If you offer or provide one or more of the above products or services, your business will be subject to AML/CTF obligations.