Diploma in Anti-Money Laundering

The Diploma in Anti-Money Laundering is designed to equip students, from a variety of professional and interested backgrounds, with an understanding of the history and nature of the money laundering and terrorist financing offences.  It also examines the special approach taken by the AML/TF legislation to prevent these offences.

Students will consider in detail the various obligations imposed by the AML/TF legislation on credit and financial institutions including, in particular, their designated Money Laundering Reporting Officers. At the end of the course, students will have a firm understanding of the legislation’s requirements in relation to, in particular, the risk-based approach, customer due diligence, reporting suspicious transactions, record-keeping, training and corporate governance.

Students will also learn about the criminal and civil enforcement procedures that await those who have been found guilty or are suspected of money laundering or terrorist financing offences.

Course Content

Lecture 1

Introduction; the rise of money laundering and terrorist financing; the initiatives that sought to keep apace

Background to money laundering and terrorist financing:

• Understanding the general concept of “money laundering” and “terrorist financing”
• Tracing the history of money laundering and terrorist financing
• Stock-taking money laundering and terrorist financing today

Comparative Study of Initiatives:

• International initiatives
• EU initiatives

Background to Criminal Justice (Money Laundering) Acts

Lecture 2

Criminal Justice (Money Laundering) Acts: The Offences and Designated Persons

Criminal Offences:

• Money laundering offences
• Other offences related to money laundering
• Terrorism
• Secondary liability

Designated Persons:

• Who is subject to AML/CTF Rules?
• Exemptions
• Entities specifically excluded

Lecture 3

Keeping Ahead of the Game: The Risk-Based Approach

• What is a “risk-based” approach?
• Applying a risk-based approach
• Legislative Basis
• Role of senior management and internal controls
• AML/CFT risk policy and procedures
• Money Laundering/Terrorist Financing Risk Assessment
• Other factors to consider in designing a risk-based approach

Lecture 4

Know your Customer or else: Customer Due Diligence

• What is customer due diligence?
• When do the customer due diligence obligations apply?
• What customer due diligence measures should be conducted?
• Timing of customer due diligence measures
• Failure to comply with customer due diligence procedures
• Simplified customer due diligence
• Enhanced customer due diligence
• Non face-to-face customer due diligence
• Special provisions applying to Credit and Financial Institutions
• Reliance on Third Parties to undertake Due Diligence

Lecture 5

Blowing the Whistle: Reporting Suspicious Transactions

• Legislative requirements
• Reporting of Suspicious Transactions
• Knowledge, suspicion and reasonable grounds for suspicion
• Timing of reports
• Protections from disclosures
• The internal reporting process
• Process for reporting to the “FIU” and Revenue Commissioners
• Tipping off
• Directions and Orders

Lecture 6

Taking Note: Requirement to keep records

• Legislative requirements
• What records should be maintained?
• Possible formats in which records may be kept
• Where and for how long should records be maintained?

Lecture 7

Knowledge is Power: Training

• Legislative requirements
• What should designated persons do?
• Additional consideration by staff

Lecture 8

Inside Out: Governance, and Internal Policies & Procedures

• Legislative requirements
• Corporate Governance Code
• Senior Management’s Responsibilities
• The role of the Money Laundering Reporting Officer (MLRO)

Lecture 9

Laying down the Law: Enforcement Procedures

• Criminal sanctions
• Monitoring of Designated Persons
• Freezing of Terrorist Funds
• Administrative Sanctions

Lecture 10

Following the Money: Civil Liability

• Conversion of stolen property
• Tracing the proceeds of crime
• Constructive trusteeship
• Knowing assistance

Assessment

A pass grade on the written assignment (worth 80%) and presentation (worth 20%) will be required for awarding of the Diploma. A fail grade will result in a Certificate of Attendance for the course but without the Diploma being awarded.

Students must attend at least 80% of classes to graduate with either the Diploma or Certificate of Attendance unless a serious and verifiable reason for further absence is provided. If completing the course online, attendance and participation is tracked through Moodle.

The assignment/project must be handed in on the due date unless a sound reason for lateness is provided. In such instances, an extension may be awarded at the discretion of the lecturer.

Successful students will be invited to attend a graduation event in Dublin in April 2020.