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[Music].hello and welcome everyone my name is.Silvia VAWA I'm a risk solutions.consultant at vicinities thank you so.much for joining us for today's webinar.on AML regulation development I really.appreciate you taking the time.especially in the current situation when.our minds are preoccupied with the.caucus 19 pandemic and the impact it's.having on our life I sincerely hope that.you and your loved ones are healthy and.safe I would like to kick off today with.a polling question in terms of system.capacity but also to see if there are.some positive aspects of the current.unknown situation you know given the.restrictions of movement and everyone's.change of focus so here's the question.the impacts of cough is 19 on the world.economy will undeniably be significant.but how do you think it will impact.financial crime a increase be the cream.or C there won't be much impact please.choose your answer now on your screen.and I'll give you 10 seconds to submit.your answers.here the results of the question on the.possible impact of the covered 19.pandemics on financial crime 19 five.point five percent of the audience.thinks that there may be an increase of.financial crime very interesting results.and I think in line with the.announcement yesterday actually in the.u.s. when DOJ filed its first.enforcement action against copied 19th.Road federal court issued temporary.restriction order against the website.offering Foodland coronavirus vaccine.interesting times ahead of us I hope.everybody will say a health and safety.and maybe our prediction will not turn.out as bad okay so before we begin with.the presentation I need to cover a few.housekeeping items first of all at the.bottom of your audience console there.are multiple application widgets if you.have any question during the webcast you.can click on the Q&A widget at the.bottom to submit your question we'll try.to get to as many questions as we can.appear if you have a technical question.however problems with audio and and so.on please can you use the question mark.icon and also remember that if the.slides are stuck you should try to.refresh the page as a first step and it.may take a few seconds for slides to.advance so please be patient secondly if.you are able to access additionally if.you would like to read a little bit more.about the topics that we are discussing.today you can access additional.resources on those topics and these are.parked in the resources section on the.right hand side and next we will send.you a recording of this webcast and also.the copy of today's slide back in a few.days time and last but not least at the.end of the webinar a survey box will pop.up I would really appreciate it if you.can take a moment to fill this out and.provide us with your feedback so without.further adieu.I'm truly delighted to facilitate the.call with the experts in the AML field.who will share the knowledge with us.today it's definitely not coincidental.that they are here today with us and I'm.really looking forward to each of the.presentation so let me introduce my.guests to you so we have with us.Aurelia Belgian and senior associates at.Cobalt and who's joining us from.Lithuania good morning Aurelia hello.everybody hello and then we have a Roger.Kaiser who's senior policy adviser at.the European banking Federation and.Roger is dialing in from Belgium today.hello Roger tell Olivia hello everyone.hi and last but not least we have in.Taunton Gemma executive has a group.sanctions desk at the standard Bank.Group and Anton tombi is joining us.today from South Africa hello Toby hello.Sylvia hello everybody so if anybody.from the audience had haven't had the.pleasure of meeting our speakers before.you can read more details about they.work and the specialization in the.speaker's bio widgets on the left-hand.side so I won't be taking too much time.for for detailed introductions today.just very warm welcome and thank you so.much for joining us today two years ago.Rison it is together with initial two.other founding members Europol and the.World Economic Forum formed the global.coalition to fight financial crime the.European banking Federation actually.recently joined the coalition so warm.welcome to Roger and his colleagues and.among the coalition's objectives and in.general for relative risks experts.knowledge exchange is one of our.priorities and especially now when.events and public gatherings have been.halted by most governments webinars are.really a great knowledge sharing method.so we've recently organized a webinar on.functions and in the coming weeks we.will also hold a third party with.webinar series called word.from clients and and sustainability.begins the first session of that webinar.is scheduled on the 28th of April so.please watch out for the registration.link on our social media profiles and.also in the follow-up email to today's.session I would encourage you to sign up.to those sessions as well so what is the.current state of affairs when it comes.to effectiveness of IML framework I've.prepared some data for illustration as.you see on this slide so we have the.first number almost three trillion.dollars it's either lost or spent on.fighting financial crime by the private.sector this number is greater than most.individual countries GDP in Europe the.statistics show that only 1.1 percent of.criminal profits are confiscated at the.uniform and when it comes to SARS.suspicious activity report they are.growing by 11 percent annually while a.whopping 97% of SARS is actually of no.immediate value to financial.intelligence unit to me these numbers.are a pretty clear demonstration that.the IMO framework needs a thorough.revision and as my guest speakers Roger.irelia and Dombey will discuss in a few.minutes activities are taking place but.I think it's important to stop for a.minute and look at fatass before we look.at the India region or the EU.specifically the Financial Action Task.Force undeniably has been the most.influential organization worldwide.developing policies to combat money.laundering and terrorism financing and.governments across the world really look.to father for the recommendations and.they do implement them although with.varying levels of psychosis so from.what's the latest from father the father.Flannery meeting was held last month in.Paris and more than 800 representatives.from around the world including IMF UN.and World Bank came together to discuss.the hot topic.so Emma and the three key areas debated.during those sessions were a virtual.assets and digital identity be specific.country's progress and see other topics.that included combating the laundering.of proceeds of the illegal wildlife.trade so I wanted to comment briefly on.those three key points the first point.digital payments a digital identity the.digital payments are growing as an.estimated twelve point seven percent.annually really there's no hiding from.this and criminals are using virtual.assets and digital channels more and.more so the IMF regime and policies will.need to respond to those new threats but.also for the sake of the effectiveness.of business the business and compliance.things should really start embracing.technology a little bit more client.onboarding procedures will need to be.adjusted for the digital era and.financial institutions are being.encouraged in some countries to apply.technology to the KYC and onboarding.processes so a great example of that.encouragement would be the statement.issued by the US concerns with Financial.Crimes enforcement network since and.encouraged in normative industry.approaches to AML compliant but most.interesting not only distinction.encourage innovation with the existing.tools and to use new technologies but.most critically it's recognized that.innovative pilot program should not.subject banks to supervisory criticism.even if the pilot program ultimately.proved unsuccessful I think it's a key.message to encourage and make sure that.nobody's going to be penalized if it.doesn't go exactly as planned.and this month part of published.guidance on how digital ID systems can.be used to conduct certain elements of.customer due diligence under its.recommendation terms I have added the.guidance the webinar resources we just.so if you haven't had a chance three.to review that spot of report on the.second point country implementation.process I wanted to share just one.example here I've actually recently.reduced the February 2025 of mutual.evaluation of 1990 addictions that look.specifically at the assessment of.immediate outcome five so I wanted to.see how a global scale countries have.been progressing in opening up registers.of beneficial ownership and leading.towards closing the big gap we have.right now the business secrecy the.government makes financial crime so much.easier to commit and the government.makes it so much more difficult to.detect financial crime so when it comes.to immediate outcome five it's really a.reflection of how well the countries are.doing implementing part of.recommendation twenty-four amount of the.ninety nine jurisdiction that were.assessed in the recent years not a.single location has performed well when.it comes to ultimate beneficial.ownership registrar's and the relevant.legislation only ten countries as you.see at the bottom of the slides were.assessed at the substantial level of.effectiveness and sadly the remaining.eighty-nine assess jurisdictions were.more or less evenly split into bad job.done and nothing done at all I'm moving.on to the third key points that I.discussed in February.Valarie meeting organized by Fattah.which was illegal wildlife trafficking I.actually think we should expand this to.environmental crime or green crime which.is generally any abuse of the.environment so not only while source.trafficking but also crimes such as.ivory smuggling illegal logging or toxic.waste something the reason why this.topic is important in the context of the.future I am a framework is because it's.not only fascist but Davos Europe all EU.us most policymakers and international.animal forms are really actively looking.into environmental crime issues I would.personally guess that similary and.social crimes moderating modern-day.slavery he.trafficking you know child labor those.tribes have gained attention and have.been reflected in local specific.regulations recently such as UK.modern-day slavery acts sometimes - in.France or in child labour due diligence.law in the Netherlands I think similarly.to what happened with regards to to.those crimes we should expect.legislation related to green crime and.its reflection in AML policies so just.to summarize these three key points as.discussed recently at the fastest.meeting I believe that AML regulations.will reflect this in the near future the.technology really needs to be embraced.by business but also by regulators in.the region then business transparency.and other recommendation needs to be.taken more seriously and implemented.effectively and we need to adjust our.thinking about predicate offense such as.environmental crime so moving on to the.EU regulation and speaking of.effectiveness of implementation of fat.of accommodation.I'll give now the floor to my first I.guess irelia who is an expert in the.field and already will share with us how.well you member states have done so far.on the 50ml directives implementation.but more importantly what is coming next.with the six iMod Aurelia welcome and.shall we start with a quick polling.question - audience yes you know thank.you the question from Aurelia is has v.IM LD been implemented in your country.please can everybody in the audience.take your answer yes no I don't know.and click Submit button now.moving on to the results so the question.has the 50 ml directly been implemented.in your country 70% of the audience said.yes and 20 percent said no and 19 sure.about about the into the level of.implementation earlier what do you think.about the results of the poll the.polling question well it's not very much.surprising I would have expected for.such results especially because of the.fact that we still have not seen the.implementation table so the only.information where we could get so from.our friends or our public information.which which was the main thought for my.my personal presentations so once again.thank you Sylvia for introducing the.topic and and the polling question and.thank you for the audience for.participating.before starting the what I wanted to say.and what I have mentioned also in all my.posts that indeed isn't the best time to.upgrade our knowledge and one poll on.earth wises results we will have even.more words and to keep our company's.going and definitely not been assigned.for upgrading our nerves so this is the.best time to discuss about AML matters.right now and in terms of implementation.of AML five Cs and six directions one.cannot deny that for anomic effect.implementation process in terms of.timings and however right now we need to.focus on two very important days so as.we already all know emails five.direction was about this in 2018 and has.to be implemented by since January 2020.where we have the six directive.implementation is affirming it was of.god adopted again in 2015 but then it.has to be implemented by December 2020.so we still have confining now regarding.public information that we have is as.well although the implementation table.is not yet published and it is not known.whether the directors has been properly.transpose in the each country's national.law we cannot deny that it makes us.therefore subsequently.Aaron says directors have been partially.from foods by the member states however.what we see right now from the.Commission that eight countries which.are included in this map these countries.have been given with a formal notice for.no notification regarding the measures.taken so it might be the case that.either these measures have not been.implemented yes or no notifications are.granted me but what happens next is that.it's it's not because I'll send the.formal reason why within three months.and the number states continue not to.comply the Commission may incite you to.clear the matter to the European Court.of Justice I do not expect that this.might happen but maybe we never know as.it has to be aware especially in terms.of the Kurama crisis which definitely.delays the processes because right now.everybody is focusing on seeking the.world on focusing on the crisis now what.we have discovered is when when checking.the implementation process in different.countries we can see that a lot of of.the countries have psychologists and so.the email g5 however it soon as well.whether it was being fully transferred.international law for example France has.only partially implemented the.directions that means of all the.official photos in its own law in 2009.in it's only only one piece of.amendments related to the directive it.has came into force this year another.sort of amendments are still under.discussion some practitioners claim that.Poland Poland polish unilaterally first.went in with an erection and as far as.we are we are and I'm myself practicing.in between Lithuania Latvia thoughtfully.to enforce the provisions of the.directives but now when we go into.separate sections or in separate.subjects I know that any time they will.deport me allowed to be eraser but some.information about it so in terms of you.being register and it's untraditional.international law it's not functioning.in form of the country.the situation for example swing is that.everybody is preparing for opening the.register the register is actually.accessed but you bill function is not.working yet and each and every year we.get a notification from the company's.renter that it will be shortly.implemented but still or not everything.calcium's and what it's an ancillary and.in terms of the swag since I've heard.that we did not get enough funding so it.made the way the process ended name is.in the UK so what we found is that the.amount of struggling due to lack of.funding technical barriers amounts of.data assessments however good news is.that in some of the countries is the ubo.answer is actual operational before the.implementation of that they like for.example in the you Bo.we're inbound anubian reserva went live.in 2015 and belgian companies right now.have to submit their their Ubu data by.thirty fourth of March I have not seen.yet data whether all this information.has been submitted but actually this was.this was one of the rules in 2019 and in.Germany the same the UB arrest is.already working since implementation of.the fourth UML directed and now what we.have also heard from the public.information is that Germany has also.implemented the directives you say.samples will be the same and as for.Malta as a multi small that has reported.that the government has given assurance.that it will be smooth fully implemented.so hopefully this is true from the sea.and sorry I'm going back you wanna.stress right now individuals individual.approach and some additional provisions.about more stringent requirements so in.Bulgaria motoring and requirements are.going to be adopted the team approach.was followed actually even in 2000 which.means in Ireland.criminal justice bill establishes.additional measures.she will support the criminal Attleboro.and Ireland National Police Service you.can regard to their flowers access bank.records and in fact of media so what we.heard and what we understand is that in.Germany compositional stress the two.likelihood says the federal.administrative office will arise.strength sir I set my standards you to.increase made media presence so this.means that in Germany it might be the.case as more stringent requirements as a.mouth of the rule applies.now as for implementation of the 6mm.direction so we already know that.Masuka France which are fine until.December and in some countries some.already started working with us and.implementing their national laws so.according to official data only the.following countries have implemented.then take me taking the measures which.you apply a ml6 directive so this is.Czech Republic sound creation Romania.from graduations with that Germany has.already also just been able to chose.sports as for this way and because I can.speak about my own country so in this.way yes some of the provisions are.already aware and already implemented.however they have to be amended for.example in Lithuania we do not have.punishment for or the punishment is not.clear for the projection of illegal.property so this will be introduced in.one of the articles implementing the.illegal possession of property gained.from from AML related related activities.and also the punishment for that.activity is only absolutely air so it.will be increased in accordance with the.direct I receive up to four years now.what what we heard about breakfast or.for breakfast is also touching this.protis following the withdrawal of you.see implementation is in question.however as far as we.or where AM L directives have been.implemented in dxn possible as for.operation protocols allow lots Nazis to.choose to participate in this Trojans.however it might be the case that either.Denmark or UK or Ireland decides to.participate in this operation soldiers.and they will be reduces and Ireland has.also decided that if you oxen and very.implementation of the amounts so this is.sustained way that is very brief and.very short presentation about the.implementation of the directions for me.actually it was very awkward.multi-sphere will not to see all all you.participate in getting this webinar.however let me see that we have any.questions leave Fulton during the Q&A.and then I will try to answer them thank.you very much brilliant thank you so.much earlier for for the detailed run.through European Member States and.before we move on to our next speaker.Roger Kaiser who's going to talk us.through European banking Federation.recent developments I have another.polling question to the audience so the.next question is what should be the.focus of the future you AML regulation.and we have three options a.clarification of the risk-based approach.the modernization of the KYC policies or.C ensuring that the scope of the.framework and converse with new.technology based businesses please.choose your answer and click Submit.button now.okay moving on to the answers to the.questions what should be the focus of.the future of the aim of regulation you.let's see the answers it looks like half.of the audience voted for ensuring that.the scope of the framework includes new.technology-based businesses and the the.remaining the two remaining answers.clarification of the replaced approach.and modernization of the KYC policy is.more or less evenly split a Roger what.do you think about the suggestions from.our audience here well certainly.interesting - um I would say regulatory.convergence it's absolutely key and and.those three aspects are equally.important and should be covered in the.new regulation I I will address those.two aspects in my presentation anyway so.allow me to briefly introduce the.European banking Federation the EBS.which is the voice of European banks the.es collectively represents the national.banking associations of European.countries including all the you Member.States the United Kingdom attack.countries which altogether represent.approximately 3,500 banks since 2016.money laundering scandals and Sachs.League has made behead life a first wave.of events in 2015 in 2015 included the.Swiss leak and the Panama papers and in.you this first raid figures a number of.initiatives among which the setting up.of a special committee by the European.Parliament and we have just talked about.that the adoption of a management.to the 4th anti-money laundering.directive the AML d5 since 2018 a.seventh wave of scandal has involved a.number of European banks impacting the.reputation of the sector as a whole this.cylindre started with the gaze of a.latvian bank a dlb which lost its.banking license and had super secret it.did therefore become apparent that money.laundering issues may rapidly become.prudential issues and may affect the.viability of a bank and the stability of.the banking sector as a whole this.seventh wave of events has triggered.among others a reinforcement of the.European Banking Authority ever and the.adoption of an action plan side council.which mandated Commission to draft a.post mortem report and to take action to.improve the effectiveness of the EU AM.lcst framework now money laundering is.defined as a process of transforming the.proceeds of crime into offensively.legitimate assets in other words to.introduce dirty money.in the official financial system however.is about much more than white-collar.crime it's often connected to organized.crime gangs and other threats which.include financial films and corruption.counter fighting and smuggling illegal.drugs crime human trafficking and.terrorism fighting financial crime and.money laundering concepts inserting.resources to criminals organized crime.gangs and to Paris.over the last few years awareness has.arisen about in effectiveness of the.current um lcst framework the European.banking Federation DVF has made its own.assessment of the EU AML TFC framework.and has identified four major challenges.ie a fault priority area where.ineffectiveness urgently needs to be.addressed.they are the regulator with.fragmentation the Supervisory.fragmentation insufficient cooperation.between the axles of the American.systems and the lack of efficient tools.and sub optimal use of technology the.EDF reached earlier this month.a blueprint for an effective new.framework to find money-laundering which.is entitled lifting the cells of dirty.money in this blueprint the EDF is.putting forward a set of 20 countries.policy recommendations related to the.four priority areas that we have.identified first we recommend to.harmonize new regulatory framework.focusing on a clarification of the.risk-based approach and a modernization.and standardization of the KYC policy.bergens we recommend to empower the.relevant EU institutions and agencies to.fight financial crime among others the.room of the European banking services.ever as a route setter is five bottl.and should be further enhanced ever will.have to provide some be harmonized.standards that will help enhance.supervisory convergence and should focus.on the mitigation of ways.it is not absolutely key to strengthen.am lcst supervision it requires further.integration of AM LTS key considerations.into Prudential supervision and more.efficient view coordination of AML CST.supervisor which may require some kind.of centralization of supervisory power.search we recommend to enable all actors.in the AML CSP ecosystem to cooperate.more efficiently coherent approach for.information sharing must be adopted.which will balance data protection and.financial crime prevention in this.respect the adoption of a new wide gdpr.AML guidance would be welcomed the.medias particularly emphasizes the need.for feedback from fi use to reporting.entities that have some suspicious.activities report and finally we also.strongly encourage the development of.public private partnerships for we.recommend to enable financial.institutions to be smarter than.criminals by deploying effective tools.and exploiting new technologies in this.respect we encourage the use of enhanced.analytics and machine learning tools for.kyc supposes and we also call for.beneficial ownership transparency to be.based on better design ultimate.beneficial owner registers banks are the.gatekeepers of the financial system they.control the access of customers to the.financial system a man from difference.of services extensively rely on banks in.the fight against financial crimes.through a series of due diligence.transaction monitoring and reporting.requirements.banks play a crucial role in detecting.money laundering related transaction and.this is why banks should be part of the.solution as ice we consider it our prime.responsibility to support the efforts of.the public sector in combating money.laundry EVs and the voice of European.banks aims to be at the forefront of.this battle thank you thank you so much.Roger and we'll move on to the last.presentation for today we have Tom be.who will now walk us through the main.challenges the institution's face with.regards to current AML regime but also.the potential opportunities with the new.directions and the new directions will.be going to somebody thank you for.joining us and before we move on to to.your presentation let's again ask.polling question to audience so here's.the question help your country set up.beneficial ownership registers the.answers are yes no I don't know fairly.straightforward answer so please submit.your answers now.so let's see what the audience says.about to the beneficial ownership.register implementation in their own.country sixty-three sixty-four percent.of audience said yes the registrar's the.hubell registers have been implemented.in their country.twenty-five percent says no no and.eleven percent says I don't know what is.your take on those answers and Tom B so.yeah thank you so much.look it's not surprising at all I was.expecting a result that looks like this.and I think just to echo what my fellow.panelists said before the challenge of.ubo registers is one that touches quite.a lot of us and at different levels but.perhaps just within.speak to to the heart of what I was.wanting to say here the the UVO issue is.an issue because through distancing ones.assets from themselves that practice.makes it very challenging for banks to.manage the risk of money laundering I.think it was yourself Sylvia and and.orally and as well as Roger that that.touched on this so it is highly highly.important for banks for governments to.assist banks by putting these type of.things in place but I'm not going to.speak much more about that but rather to.speak to the opportunities that that are.there for banks to explore all of us.know and especially with this covert 19.endemic now going that the fourth.Industrial Revolution presents a heck of.a lot of opportunities for us to.leverage and the concept of ultimate.beneficial ownership does not escape.both the challenges and the.opportunities that come with with you do.what I just wanted to highlight to the.audience is some out-of-the-box thinking.and some out-of-the-box thinking.specifically in the Utopia the perfect.work of the way we all have functional.ubo registers in that world there exists.a very many opportunities specifically.from a big data handling perspective for.us to do quite a lot as financial.institutions I don't know how much of.the audience knows about structured and.unstructured data but again not looking.to explain those concepts the.opportunity that I wanted to speak to is.that when you have financial.institutions that have geared themselves.up to in to interact with fair data from.a structured perspective we could run.algorithms on our ubo data that would.make the following things quite much.more simpler than what we're doing now.sanction screening from the perspective.of the effect.50% true and the effects sectoral.sanctions quite it's quite a challenge.for most of us right now but if you were.to combine your ubo compliance from a.directive perspective with your 4ir.capability as a bank and start.interrogating that structured data.determining things like is this company.helps 50 percent or more by Ofek.sanctioned entity becomes far more.easier than it is today.determining things like as this.particular entity fall foul of the.effects sanctions factorial sanctions.rather becomes far more easier than it.is today.like everything else sanctions screening.is also then coupled with our capability.to route to report on sales and again.here in the perfect world we will all.have functional ubl registers the.opportunities that exists for Bank are.the data mining algorithms that we can.apply to that data to make our.monitoring activities so much more.effective this is where you can pick up.on complex patterns that would show you.suspicious activity that's happening.even though the ubios in those.particular scenarios are going through a.great length of complexity to try and.mask their true nature again what are.the challenges the challenges are do we.have functional registers in the invert.in the different countries other sets of.challenges are have our institutions.fully embraced the fourth Industrial.Revolution and are working full steam.ahead to enable themselves to.interrogate interrogate structured.unstructured data to use data handling.models I know a lot of what I'm saying.right now is not a natural language for.AML CFT offices but I shall see a world.that has both challenges and.opportunities that's going to overtake.us soon where compliance officers are.needing to speak this language more so.in the future than right now.so then chill internet Silvia if you.yeah sorry I was I was on you thank you.so much and don't be so and let move on.to one more polling question a little.bit more specific here that's your.financial institution Bank any.cryptocurrency dealers and again.straightforward answers a yes B no C I.don't know once you pick your answer.please click on submit button and we.move on to the results that your.financial institution Bank any.cryptocurrency dealer from there you go.84 percent of the audience says no what.do you think of that income be sure.again not a surprise so the thing with.cryptocurrency dealers is I think as.financial institutions we are all in the.same boat there's a popular and a very.true narrative that says that.cryptocurrency based cryptocurrency.based currencies function from the.perspective of giving the users a great.deal of anonymity again as Mr C of T.practitioners we can all agree that what.we do is founded on the cardinal.principle of being able to identify and.verify who you are dealing with and by.design these crypto currencies give the.the holders of those assets the ability.to stay anonymous so the fact that this.high percentage of noses coming in is no.surprise at all and I suppose in that.lies the very challenge that banks are.needing to deal with how our financial.institutions meant to interact with this.fast growing and I think again at the.beginning of the presentation survey I.think it was you who spoke to it we are.not going to be able to escape as.financial institutions this movement of.crypto assets it is growing and it will.continue to grow the challenge how do we.then deal with it when inherently this.product comes with the ability to give.its users anonymity I'll give you some.insights in terms of what we are doing.in South Africa so from a South Africa.perspective my colleagues and I are part.of a over a part of a working group that.our FIU and our regulator has set up and.at this working group FIU and regulator.have put it very plainly on the table to.say guys there's another challenge that.we as regulators are going to need to.partner with yourself to actually get.over the hurdle of looking at this.what's interesting is that the regulator.has opened up their doors to say banks.you have very large research teams you.are very much in the middle of this.financial activity we are looking to you.to bring to us any ideas that you may.have in terms of how is it best to.regulate this particular space what's.interesting as well is that we also have.a few crypto nsaids dealers that have.joined that working group and they have.actually said we want to be regulated we.don't want to be looked at as this risky.product that everybody is trying to run.away from so what are the what are the.opportunities that exist.I invite you as my fellow AMR CFD.practitioners to perhaps look out for.those opportunities in your own.jurisdictions in your own countries.because I really think that in the very.near future if it's not already.happening in your space your own.regulators and your own fi you might.reach out to you and say listen as a.financial institution are you interested.to partner with us in trying to wrap our.heads around how do we manage the AML.CFT risk that is presented through these.products I wouldn't want to go any.further into the honest I don't have.much to say and and it is also time for.me to heads back to Sylvia in terms of.opening the floor for further questions.I think Thank You Sylvia.thank you so much in the middle really.interesting and we do have quite a few.questions coming in on the chat so if.you have a question please click on Q&A.widget at the bottom of the page and.submit your question there we may not.have the time to go through all of the.questions but we will do our best and.then we can follow up by by emails to.those questions that we haven't had a.chance to answer so let me go let go to.back to Roger and the regulation one.question Roger submitted was do you.think the EU needs to move towards a.regulation instead of directive would.your take on that yes well I am there.well today today the EU AML CFD.framework is based on directives which.provides for minimum harmonization and.this has so far left quite significant.divergences between member states in how.they have implemented and interpreted.the rooms so yes we we think we are.favored of a regulation which would take.over at least to the extent possible the.content of the AML D and was - - which.would take back the core principles of.the AML D and they are a number of of.advantages for that because that will.that will help harmonization that would.help develop more effective.policies and processes for financial.institutions that operate across folder.or worldwide that will facilitate.cross-border supervision and.public-private cooperation and as.notably this will also prevent criminals.who are to use those jurisdictions which.are the weakest and which have adopted.the risk biggest option in the.transposition so yes very much in favor.of a directly applicable regulation.Thank You Roger.and actually there's another question.that's a little related I mean quite.realize that the question is if we.should go for enhance supervisory.coordination by giving EB a more power.but but also responsibility remains at.national level or should we go for.centralization of power at EU level so.for instance ECB or new AM l EU.Authority yeah well what is clear is.that the world of Supervisors in AML's.est should be reinforced so a massive.consideration must be better integrated.into Prudential supervision now we also.need to resolve the problem of.supervisory fragmentation we we need.supervisory convergence and doing that.we we are in in the opinion that we.should focus on managing the risk that's.very important and we we indeed ins a.more efficient coordination between.national am LCS.supervisor now whether it should take.the form of a centralization of the.supervisory power I would say most.probably.but they are a number of options to do.that I think there are three options.that are still discus a political level.some talk about a bar others talk about.the European Central Bank the third.option being to create a new agency I.think the decision is not not yet.fulfilling nature on that now what what.I think should should be taken into.consideration if this so-called more.coordination and a possible.centralization of supervisory powers has.to materialize through a new body of new.powers for an existing body it's very.important that the mandate is clarified.as from the Sun for example we need to.know whether there will be oversight.responsibilities for a new body we need.to clarify what will be the relationship.with local supervisors and with banking.groups and banks individual banks and.also if this coordination is.materialized through a mandate providing.for direct supervisory powers of a bank.it seems very important not to duplicate.supervision and we also need a very.broad scope of these supervisory powers.including all member states and.including all the blood and EQ.interesting thank you so much for for.your views for sharing.and I mean much is that that's desirable.that that's further down the line but I.think we've got some other questions.regarding closer future so particularly.to Aurelia regarding the 60ml directive.because that's what's ahead of us as the.next step right there are questions on.the chat coming regarding the.requirements listed in 6ml directive.which I don't know if you can maybe.briefly list those and and also.questions regarding how the.implementation will unfold what what do.you think looking at the observing the.specific ml the for family and the CFM.of the implementation of countries.lagging behind schedule what do you.think's going to happen with the 6mm LD.when when the deadline kicks in thank.you very much for the question though.this is a tough one I'm very happy about.this one because well my presentations.presentation covers you know very very.theoretical things about implementation.and which countries have implemented and.which not here is a very material.question well with the 60 ml directive.is a bit different from the fourth and.this is when we talk about the course.and the trip we talk about specific.rules that are applicable to the due.diligence to the implementation of.simple AML measures but six directive is.completely different it talks about.criminal rule and even I myself I'm not.well qualified to talk about criminal.matters but what we can understand here.is as well the intention is to are.harmonized EU law and of national.country just you to be assuring that all.these activities that are related with.money laundering matters these are.activities are punishable and the.punishment itself is is long enough to.cover these matters so this is what is.covered there and the walls if if you.open the directive itself you will see.that a lot of activities are in this.area and these activities are punishable.and should be implemented in all.national laws as as hospitals and all.what we can see is that one important.thing that aiding abetting inciting and.the chanting of these activities we.should be punishable so not in all.countries all these ivities are.punishable so as of implementation of.the directive we should change now as.for your question whether whether we.rotate any issues with the.implementation itself not for religious.part of the reasons might be well the.karana crisis as I mentioned was itself.is that it is not related in any way but.since what we have seen in our country.and which as we are seeing and facing.the same in other countries is that the.primary focus right now is to combat the.Quranic license and for that reason a.lot of amendments to the Lord are.upcoming.so this is where our Parliament's are.currently focused on so this might might.be a new challenge especially that a lot.of public institutions are working in.from distance so that means that not all.the meetings I carry such out right now.and of course another thing is that this.is a criminal law and the distance.related to you smarter than AML law.itself but this is related with the.changes to the criminal law of.Challenger.well just may delay the service because.a lot of traditional institutions will.catch it in Rome to make sure that the.director is properly implemented so this.is at least my accident thank you so.much I personally slightly disagree with.the impact that coronavirus might happen.on the implementation when we look at.the deadlines I mean the deadlines 450ml.transposition past in January right so.you could you could argue that yes of.course it will delay.procedures going forward but if the.countries had taken appropriate measures.upfront you know when the FIFA FIFA MLB.was published in 2018 and had been given.two years for the implementation which.probably the results by now would have.been different right sure this is also.true this is the different views so as.it has.and of the country's you know in some of.the countries the program is very fast.in some of the countries it's slow so in.the countries where the process is very.slow you know they won't be searching.for the reasons to do it yeah.interesting thank you so much Aurelia.and don't be I have some questions to.you as well if you don't mind so one.question was regarding to the current I.am a regime will it ensure integrity.requirements for wallet providers yeah.so what's interesting is that one it.provided a very a very technically.technologically advanced sort of.entities and one always needs to remind.them that although they are doing shall.I call it banking or financial services.in a vault in a very fourth Industrial.Revolution kind of way they are still.bound to the sort of cardinal rules.around kyc what I find in my space is.that when we speak to these wallet.providers we are having to do things.very differently and sometimes people we.do them so differently that sometimes.people think that the cardinal rules of.kyc do not apply to sort of wallet type.providers they do apply to all that type.providers it's just been very very very.differently one of the ways for instance.in my personal experience we've been.able to do something from a sanctioned.screening perspective is to work on an.exception basis in terms of how do we.deal with screening of alerts and the.like so very simplistically what I'm.saying is that wallet providers were in.my face given a a IP open IP to Co and.given sanctions information and research.to them that you're going to have to run.an algorithm during your onboarding.process to ensure that you're getting a.status of the people you are on boarding.as to whether they're subject to.sanctions or not but.because these wallet providers don't.have massive teams like financial.institutions due to work the alerts that.they're getting the algorithm that they.are using looks very very different from.the algorithm that we are using within.banks there is a lot more restrictive in.that if you almost even look like a hit.is that where they actually stop your.onboarding process and they enter into a.into a sort of different process that.they run but do I think that the.directive will ensure compliance I think.it was Roger who said it when he said.that banks are a very political part of.the fight against AML and CST.and it is it is likewise in the wallet.space the compliance offices that either.service those entities alone or if they.are using their services through bank.those compliance officers are going to.have to be so much more forward-thinking.in how they ensure that these wallet.providers actually comply with kyc great.thank you so much in tow before this.unfortunately we've run out of time so.we won't be able to answer more.questions but we will try to follow up.by email and this brings us to the end.of the webinar so my last job here is to.say big thank you again to aurelion.tambien roger for your participation.also thanks to Katie for looking after.at some technical side of things today.and big thank you to everyone for Diane.amine and for your engagement during the.webinar we will reach out to everyone.following the webinar with the slides.and the recording of this session and.we'll get back to to end it as many.questions as we can that we didn't.manage to answer now hopefully see you.all on another webinar soon thank you.very much.

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Kaiser Directive Form FAQs

Here are some frequently asked questions along with their answers to clear up the doubts that you might have.

Need help? Contact support

Do military members have to pay any fee for leave or fiancee forms?

First off there are no fees for leaves or requests for leave in any branch of the United States military. Second there is no such thing as a fiancée form in the U.S. military. There is however a form for applying for a fiancée visa (K-1 Visa)that is available from the Immigration and Customs Service (Fiancé(e) Visas ) which would be processed by the U.S. State Department at a U.S. Consulate or Embassy overseas. However these fiancée visas are for foreigners wishing to enter the United States for the purpose of marriage and are valid for 90 days. They have nothing to do with the military and are Continue Reading

How can I fill out Google's intern host matching form to optimize my chances of receiving a match?

I was selected for a summer internship 2016. I tried to be very open while filling the preference form: I choose many products as my favorite products and I said I'm open about the team I want to join. I even was very open in the location and start date to get host matching interviews (I negotiated the start date in the interview until both me and my host were happy.) You could ask your recruiter to review your form (there are very cool and could help you a lot since they have a bigger experience). Do a search on the potential team. Before the interviews, try to find smart question that you are Continue Reading

How do I fill out the form of DU CIC? I couldn't find the link to fill out the form.

Just register on the admission portal and during registration you will get an option for the entrance based course. Just register there. There is no separate form for DU CIC.

How do you know if you need to fill out a 1099 form?

It can also be that he used the wrong form and will still be deducting taxes as he should be. Using the wrong form and doing the right thing isnt exactly a federal offense

Does anyone on Quora have Kaiser? Should I fill out the third party liability form for Kaiser for a car accident if is not my fault and I am waiting for settlement? My auto insurance simply said keep track of bills but Kaiser form is confusing.

If a third party is responsible, Kaiser will pay the bill and then subrogate the claim. That means that any judgement you receive will be used first to pay back Kaiser and then go to you.

How can I make it easier for users to fill out a form on mobile apps?

Make it fast. Ask them as few questions as possible (don't collect unnecessary information) and pre-populate as many fields as possible. Don't ask offputting questions where the respondent might have to enter sensitive personal information. If some users see you collecting sensitive information, they might not be ready to share that with you yet based on what you are offering, and they will think twice about completing the form.

What are the 3 types of advance directives?

The first thing should be to first look for the question they want to post. It is irritating to see the same question over and over on any subject. The second should be to check spelling, grammar, and word usage. I feel very pessimistic for the state of the world to see words like their, they’re, and there being confused with each other.

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