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Conflict affected/high risk areas and enhanced due diligence
A parallel with Swiss AML-CFT Regulation
OECD, Paris, May 4, ...
MKS PAMP GROUP
Swiss AML-CFT Due Diligence Procedures and Key
Organizational Success Factors
Global
reputation/
legal risk...
MKS PAMP GROUP
Swiss AML-CFT risk based approach: General and
enhanced due diligence requirements
All business
relations
•...
MKS PAMP GROUP
Swiss AML-CFT Regulation: High risk criteria examples
High risk
criteria
Business
relations
Transactions
Lo...
Thank you
This presentation is confidential and should not be replicated
or distributed without the permission of MKS PAMP...
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PAMP presentation - 9th Multi-stakeholder Forum for Responsible Mineral Supply Chains

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This presentation was made by PAMP during the session "Conflict-affected and high-risk areas as indicators for enhanced due diligence" of the 9th Multi-stakeholder Forum for Responsible Mineral Supply Chains, held in Paris on 4-6 May 2015.

Find out more at http://mneguidelines.oecd.org/icglr-oecd-un-forum-paris-2015.htm

Publicada em: Governo e ONGs
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PAMP presentation - 9th Multi-stakeholder Forum for Responsible Mineral Supply Chains

  1. 1. Conflict affected/high risk areas and enhanced due diligence A parallel with Swiss AML-CFT Regulation OECD, Paris, May 4, 2015
  2. 2. MKS PAMP GROUP Swiss AML-CFT Due Diligence Procedures and Key Organizational Success Factors Global reputation/ legal risks mgt Define high risk criteria Risk based approach due diligence Senior Executive Body approbation process On going monitoring Effective Compliance Department Effective training Record keeping Reporting to FIU Responsibility of the most senior executive body Policy and procedures Independent audit Segregation of duties
  3. 3. MKS PAMP GROUP Swiss AML-CFT risk based approach: General and enhanced due diligence requirements All business relations •General due diligence requirements •Identity verification, beneficial owner identification, KYC profile, etc. High risk business relation •Enhanced due diligence requirements •Additional investigations, means of investigation, timing to perform such investigation •Approbation by Senior Executive Body at account opening and yearly review High risk transaction •Enhanced due diligence requirements •Additional investigations, means of investigation, timing to perform such investigation
  4. 4. MKS PAMP GROUP Swiss AML-CFT Regulation: High risk criteria examples High risk criteria Business relations Transactions Location, nationality Country of origin/destination Type or location of activity Type of business relationship No visit Transaction volume PEP Unusual transaction based on: - Similar business relation - Previous transactions High volume transaction Cash transaction Criteria defined should fit business specificity and be formalized into policy Criteria based on country/ area
  5. 5. Thank you This presentation is confidential and should not be replicated or distributed without the permission of MKS PAMP GROUP.

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