- What is Source of Funds (SoF) and Beneficial Ownership?
a. What is Source of Wealth (SoW)?
b. Understanding the difference between the two terms and requirements.
c. What is Beneficial Ownership
d. Understanding the different ownership structures
- The FATF Recommendations
a. Customer Risk Assessment
b. Customer Due Diligence
c. PEPS, Relatives and Close Associates and other High Risk Customers
d. Enhanced Due Diligence
- The Wolfsberg Group Guidance
- Policy and Procedure
a. Customer Types, Income Types, Wealth types
b. Enquiring about somebody’s fortune
c. Examples of good and poor practice
- Verification of SoF and SoW
a. Questions to ask
b. Publicly available information
c. Adverse Media
d. Red Flags including Auditor Qualifications to Financial Statements
e. Documentary evidence types to corroborate SoF and SoW types
How far back to go
- Identifying and Verifying Beneficial Ownership Information
a. Beneficial ownership information
b. Distinction between legal ownership and beneficial ownership
c. Beneficial ownership through ownership interests.
d. Beneficial Ownership through Control/Other Means (“beyond the threshold”)
e. Beneficial ownership in respect of different types of legal persons
- Documenting a SoW memo
a. What is a SoW memo?
b. Examples of good and poor practice
c. The SoW storyline
- Case studies