STONEHAGE ALWAYS THERE STONEHAGE ALWAYS THERE

28 JANUARY 2009

4th Manx State of the Nation Fraud and other Financial Crime

THE REGULATORY ENVIRONMENT

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A NEW EUROPEAN PARADIGM

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A paradigm shift

Which requires you to translate

High level rules into internal rules

The compliance officer’s role: Changes from adherence to rules to designing systems that work.

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MONEY LAUNDERING REGULATION BUILDING BLOCKS – SUBSTANTIVE

Customer due diligence • Simplified, enhanced or reliance

• Trigger events

Monitoring • Transaction monitoring

• Enhanced ongoing monitoring

• Updating information

Other • Communication/Training • Reporting

• Record keeping

MONEY LAUNDERING REGULATION BUILDING BLOCKS – PROCEDURAL

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COMPLIENT MESSAGE BOARD

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“We review all high risk accounts every year in January; however the majority of accounts will not have changed so effectively an IT dump of all new accounts opened since the previous January will give you the most important accounts for review.

We then weed out any accounts that have not been active in the last 12 months and either archive/close or block them and make contact with the RMs to discuss the need for their continued operation. For medium risk we follow the same format but on a two year basis.

Also as part of the monthly account opening review we second check all high and medium risk accounts opened in the month and 20 per cent of low risk accounts on a dip sample basis that have been cleared by the account checking team.”

STONEHAGE ALWAYS THERE STONEHAGE ALWAYS THERE

4th Manx State of the Nation Preparing the defences – training and competency

28 JANUARY 2009

COMPLIANCE INSTITUTE QUALIFICATION

I Warwick Business School is one of the top 3 business schools in the UK.

I Centre for Business Technology, Leadership and Management (“CBTLM”) combines applied academic research to real life and technology issues.

I Centre for Business Technology, Leadership and Management supports the Compliance Institute qualification.

I Qualification is based on regulatory requirements and current compliance and industry practice

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COMPLIANCE INSTITUTE QUALIFICATION

I Its practical. Mainly case studies presenting problems faced by Compliance Officers / MLROs.

I The key to success is the candidate's ability to analyse the problem, identify the risks, and propose practical workable solutions.

I Examinations are very much a test of an individual's practical

competence. Therefore a good indication of an individual's likely workplace skills. In this way, the qualification is distinguished from others in the market place.

I Possibility that the qualification will lead (on the basis of credits per subject) to a Warwick degree.

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EXAMINATIONS

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EXAMINATIONS

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QUALITY CONTROL

I Examiners set exam paper and provide marking scheme.

I Moderator reviews exam paper and marking scheme.

I Centre for Business Technology, Leadership and Management undertakes 2nd review.

I Examiner marks scripts and moderator independently remarks sample and marginal scripts.

I Quality or marking reviewed by Centre for Business Technology, Leadership and Management.

I Whole assessment process also reviewed by Centre for Business Technology, Leadership and Management.

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BIOGRAPHY

Irwin SpilkaDirectorLondon

Irwin is a Director of Stonehage responsible for internal audit and compliance. Irwin joined the Stonehage Group in 2000 from Legal and General Investment Management. He was previously with Old Mutual for twenty years.

Irwin is a non practising Attorney with a Master of Science in Training from Leicester University and a Master of Science in Financial Services Regulations from London Guildhall University. Irwin is also a Fellow of the Securities and Investment Institute. Irwin was until recently an external examiner for the BA (Hons) degree in financial services at Bournemouth University.