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From Detection to Submission: the Art and Style of a Well-Written SAR-Suspicious Activity Report
- 8 CPD Units
- 8 Hours
- Live Online
- 24 January 2025
- 09:00 – 17:00 UK Time
- Online
£834.00
Training Outline
SAR reporting:
- What constitutes good reporting or bad reporting
- Importance of financial leads for the regulator
- Components of the international regulatory compliance framework
- Evidence vs indicator-based SARs
Foundations of AML/CFT and sanctions programs:
- Reporting entities: Banks, Non-Bank Financial Institutions, & Designated Non-Financial Businesses and Professions (DNFBPs)
- Modus operandi of UBO identification in complex ownership structures
- Divestment or Sham investment as a sanctions evasion technique requiring SAR filing
- Traceable accounts as an EDD measure for high risk profiles
- Compliance with UNSCRs, OFAC, & EU sanctions and other autonomous regimes
- Disclosure of SAR information and statistics to your correspondents: option or obligation!
Dealing with Suspicious indicators:
- The specifics of SARs related to Anti-bribery and corruption indicators and PEP exposure
- Operationalization of “attempted” vs “completed transactions”
- Scope of “Reasonable grounds to suspect” and “reason to know”
- Core Elements of the investigation process
- Reaching out to clients for supporting documents while adhering to “tipping off” principle (FATF R 21)
Post SAR filing actions and duties:
- FIU feedback and methodology in coming back to REs whether suspicion materializes or not
- Implementing freezing/blocking orders
- EDD to be practiced on blocked accounts with effective internal controls to protect financial integrity
Establishing Whistleblowing mechanism to bolster SAR reporting:
- Components and management of whistleblowing system
- The Buy-in from BODs and incident reporting to the concerned board committees
Industry Expert | Shawki G. Ahwash- CAMS,CGSS
Shawki brings under his belt 20+ years of banking experience spanning multiple areas like cross-border payments and investigations, trade finance, customer onboarding and KYC operations, correspondent banking, and last but not least AML/CFT & sanctions compliance. In his compliance function, he assumed Money Laundering Reporting Officer (MLRO) and Chief Compliance Officer (CCO) functions and responsibilities for 10 years within Lebanese banking sector.
In parallel, Shawki is a University lecturer, speaker, and trainer at: Union of Arab Banks (UAB), ACAMS, Romanian Banking Institute (RBI-Bucharest), OECD/Paris, Governance Dynamics (UAE), General Council for Islamic Banks and Financial Institutions (CIBAFI)-Bahrain, Emirates Institute of Finance (EIF-UAE), and other organizations tasked with countering money laundering, terrorist financing, sanctions evasion, & proliferation finance. Moreover, he is an adjunct trainer at PwC’s academy in Dubai & have been contracted as subject matter expert with other big 4 consultancy firms in London and KSA to render AFC services in different aspects.
As an ACAMS Certified Anti-Money Laundering Specialist (CAMS) and Certified Global Sanctions Specialist (CGSS), he has designed and delivered a diverse array of training programs addressing sanctions due diligence, AML/CFT threats, TBML, & ABC-Anti-Bribery & Corruption in MENA, GCC, and Europe. Also during his engagements as SME in consultancy projects in East Africa, Shawki had contributed to building & strengthening AFC capacities of FIUs and other competent authorities.
Among his other certifications, Shawki holds Combating Financial Crime (CFC) certificate from Chartered Institute for Securities & Investment (CISI)-UK and teach their course throughout the region. On the academic level, he holds a Master’s degree from American University of Beirut (AUB) in Public Administration.
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