Tests targeting briefing under ft. Test of knowledge testing of employees of organizations carrying out transactions with funds. Typical mistakes made by organizations and individual entrepreneurs when checking the Prosecutor's Office

T E S T

checking the knowledge of employees of organizations carrying out transactions with monetary funds or other property of the requirements of the legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism

1. Legalization (laundering) of proceeds from crime is:

a) possession, use or disposal in cash or other property obtained as a result of the commission of a crime.

b) giving a legal form to the possession, use or disposal of monetary funds or other property obtained as a result of the commission of a crime of a property nature;

c) giving a legal form to the possession, use or disposal of monetary funds or other property obtained as a result of the commission of a crime, with the exception of crimes provided for in Articles 193, 194, 198, 199, 199.1 and 199.2 of the Criminal Code Russian Federation;

2. Financing of terrorism is:

a) the provision or collection of funds or the provision of financial services with the knowledge that they are intended to finance an organized criminal community and its organizations, the preparation and commission of crimes provided for in Articles 206, 193, 194, 198, 199, 199.1 and 199.2 of the Criminal Code of the Russian Federation ;

b) the provision or collection of funds or the provision of financial services with the knowledge that they are intended to finance the organization, preparation and commission of at least one of the crimes provided for in Articles 205, 205.1, 205.2, 206, 208, 211, 277, 278, 279 and 360 of the Criminal Code of the Russian Federation, or to provide for an organized group, an illegal armed formation or a criminal community (criminal organization) created or created to commit at least one of these crimes;

c) the provision or collection of funds or the provision of financial services with the knowledge that they are intended to finance the organization, preparation and commission of at least one of the crimes provided for in Articles 205, 205.1, 205.2, 206, 208, 211, 220, 221, 277, 278, 279 and 360 of the Criminal Code of the Russian Federation, or to provide for an organized group, an illegal armed formation or a criminal community (criminal organization) created or created to commit at least one of these crimes;

3. Internal control is:

a) the activities of organizations carrying out transactions with monetary funds or other property, to identify transactions subject to internal control;

b) the activities of organizations carrying out transactions with monetary funds or other property, to identify transactions subject to mandatory control;

c) the activities of organizations carrying out transactions with monetary funds or other property to identify transactions subject to mandatory control and other transactions with monetary funds or other property related to legalization (laundering) of proceeds from crime and the financing of terrorism.

4. Organization of internal control is:

a) a set of measures taken by organizations carrying out transactions with monetary funds or other property, including the development of internal control rules, the appointment of special officials responsible for the implementation of internal control rules;

b) a set of measures taken by organizations carrying out operations with monetary funds or other property, including the development and approval of internal control rules and programs for its implementation;

c) a set of measures taken by organizations carrying out operations with monetary funds or other property, including the appointment of special officials responsible for compliance with the specified rules and the implementation of the specified programs.

5. Implementation of internal control is:

a) implementation of the rules of internal control and programs for its implementation by organizations carrying out operations with monetary funds or other property, as well as compliance with the requirements of the legislation on documentary recording of information (information) and their submission to the authorized body, on the storage of documents and information, on the preparation and training of personnel;

b) implementation of the internal control rules by organizations carrying out transactions with monetary funds or other property, as well as compliance with the requirements of the legislation on the identification of customers, their representatives, beneficiaries, on documentary recording of information (information) and their submission to the authorized body, on the storage of documents and information on training and education of personnel;

c) implementation of the rules of internal control and programs for its implementation by organizations carrying out operations with monetary funds or other property, as well as compliance with the requirements of the legislation on the identification of customers, their representatives, beneficiaries, on documentary recording of information (information) and their submission to the authorized body.

6. Does the prohibition on informing clients and other persons about the measures taken to counter the legalization (laundering) of proceeds of crime and the financing of terrorism apply to measures aimed at countering the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) no, it does not apply, there is no such obligation;

b) yes, applies only to persons in respect of whom there is information about their involvement in extremist activities or terrorism, or a legal entity directly or indirectly owned or controlled by such an organization or person, or an individual or legal entity acting on behalf of or at the direction of such an organization or person;

c) yes, it does.

7. A transaction with monetary funds or other property is subject to mandatory control if:

a) the amount by which it is performed is equal to or exceeds 600,000 rubles, or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the provision of interest-free loans to individuals by legal entities that are not credit institutions and (or ) other legal entities, as well as obtaining such a loan;

b) the amount by which it is performed is equal to or exceeds 3,000,000 rubles or is equal to or exceeds the amount in foreign currency equivalent to 3,000,000 rubles, and by its nature refers to the provision of interest-free loans to individuals by legal entities that are not credit institutions and (or ) other legal entities, as well as obtaining such a loan;

c) the amount by which it is performed is equal to or exceeds 600,000 rubles or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the provision by legal entities that are not credit institutions of any loans to individuals and (or ) other legal entities, as well as obtaining such a loan;

8. A transaction with monetary funds or other property is subject to mandatory control if:

a) the amount for which it is performed is equal to or exceeds 600,000 rubles or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by a person to the authorized (pooled) capital of the organization of funds;

b) the amount for which it is performed is equal to or exceeds 600,000 rubles or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by an individual to the authorized (pooled) capital of the organization of cash in cash ;

c) the amount for which it is performed is equal to or exceeds 600,000 rubles, or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles, and by its nature refers to the contribution by a legal entity to the authorized (pooled) capital of the organization of cash in cash ;

9. A transaction with immovable property is subject to mandatory control if:

a) the amount by which it is performed is equal to or exceeds 3 rubles or is equal to or exceeds the amount in foreign currency equivalent to 3 rubles, and the result of its commission is the transfer of ownership;

b) the amount for which it is performed is equal to or exceeds 600,000 rubles or is equal to or exceeds the amount in foreign currency equivalent to 600,000 rubles;

c) it is made by paying with securities in the amount of 600,000 to 3 rubles;

10. The client must be identified if he:

a) only performs an operation (transaction) subject to mandatory control;

b) only if employees of an organization carrying out transactions with monetary funds or other property, on the basis of the implementation of internal control programs, have suspicions that any transactions are carried out for the purpose of legalizing (laundering) proceeds from crime or financing terrorism;

c) performs any operation (transaction), except for the implementation by an individual of an operation to buy or sell foreign currency in cash for an amount not exceeding rubles or not exceeding an amount in foreign currency equivalent to rubles;

d) A and B are correct.

11. In what case is the special executive will meet the qualification requirements:

a) the presence of higher professional education in the specialty "Jurisprudence", confirmed in accordance with the established procedure, training in order to counter the legalization (laundering) of proceeds from crime, and the financing of terrorism in the form of unscheduled instruction;

b) having work experience of at least two months in positions related to the performance of duties to counter the legalization (laundering) of proceeds from crime and the financing of terrorism and undergo training in order to counteract the legalization (laundering) of proceeds from crime and the financing of terrorism in the form of targeted briefing;

c) the presence of a higher vocational education in specialties belonging to the group of specialties "Economics and Management", or in the specialty "Jurisprudence" belonging to the group of specialties "Humanities and Social Sciences", confirmed in the prescribed manner, and in the absence of the specified education - work experience of at least two years in positions related to the performance of obligations to combat the legalization (laundering) of proceeds from crime and the financing of terrorism and undergo training in order to combat the legalization (laundering) of proceeds from crime and the financing of terrorism in the form of targeted briefing.

12. What kind of briefing is in question, if it is carried out by a special official when hiring for a position or for perform functions specified (specified) in clauses 3, 4 of the Regulations, and when translating ( temporary transfer) to positions or to perform the functions specified (specified) in clauses 3, 4 of the Regulations.

a) planned;

b) unscheduled;

c) target;

d) introductory.

13. One-time training for AML and CFT purposes in the form of targeted briefing is provided for:

a) special officials;

b) heads of organizations (branch);

c) deputy heads of organizations (branches);

e) head legal unit or a lawyer of the organization;

f) true a, b, c, d, e;

g) true a, b, c, d.

14. For how long is the organization obliged to suspend the operation if at least one of the parties is the organization or individual, in respect of whom there is information received in the prescribed manner about their participation in terrorist activities, or a legal entity directly or indirectly owned or controlled by such an organization or person, or an individual or legal entity acting on behalf of or at the direction of such an organization, or faces:

a) for three working days;

b) for two working days;

c) for 10 working days.

15. What regulatory document defines a unified approach to the development of organizations (with the exception of credit institutions) carrying out transactions with monetary funds or other property specified in Article 5 of the Federal Law of 01.01.2001. , the rules of internal control carried out in order to counter the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) Order of the Government of the Russian Federation of 01.01.01;

b) Order of the Government of the Russian Federation of 01.01.2001;

c) Resolution of the Government of the Russian Federation.

16. Organizations carrying out transactions with monetary funds or other property in accordance with the rules of internal control are obliged to document the information obtained as a result of the application of these rules and the implementation of internal control programs, and to maintain its confidentiality, while the grounds for documentary recording of information are:

a) the confusing or unusual nature of the transaction, which does not have an obvious economic sense or an obvious legitimate purpose;

b) inconsistency of the transaction with the goals of the organization's activities, established by the constituent documents of this organization;

c) identification of repeated performance of operations or transactions, the nature of which gives reason to believe that the purpose of their implementation is to evade the mandatory control procedures provided for by this Federal Law, other circumstances giving grounds to believe that transactions are carried out in order to legalize (launder) income received crime, or terrorist financing.

d) only A and B are true;

e) only A and B are true;

f) A, B and C are true.

17. Who supervises the implementation of the Federal Law of 01.01.2001 N 115-FZ "On Counteracting the Legalization (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism":

a) Rosfinmonitoring;

b) the Prosecutor General of the Russian Federation and prosecutors subordinate to him;

c) the President of the Russian Federation;

d) the Government of the Russian Federation.

The condition for performing the test is that only 1 answer can be correct.

Targeted training on AML / CFT, raising the level of knowledge in the field of financial monitoring and other forms of training: practical recommendations for completing training

P.A.SMISLOV:

Targeted training on AML / CFT, raising the level of knowledge in the field of financial monitoring and other forms of training:

How and where to get targeted training. practical advice from a financial monitoring expert, a specialist in educational activities in the field of AML / CFT Pavel Smyslov for training

(article for jewelry organizations, real estate agencies, leasing and factoring organizations, operators for receiving payments)

Training to combat money laundering and terrorist financing (AML / CFT training) is one of the favorite responsibilities of many organizations that are subject to the requirements of anti-money laundering legislation.

Indeed, for many, targeted instruction on AML / CFT is always a whole event: you need to come to the training center, listen to a fascinating and useful lecture for a whole day, and upon its completion, receive a certificate printed on a beautiful letterhead, which you can then hang on the wall in your office and brag to colleagues: "now I know everything about financial monitoring and AML / CFT!"

However, as the practice of the author of this article shows, who is a lecturer of targeted briefings and raising the level of knowledge both in the Interregional Training and Legal Consulting Center for Financial Monitoring established by him, and in other partner training centers that regularly invite him to lecture with pleasure. training is still a very weak link in the internal AML / CFT control system in organizations and among entrepreneurs who do not fully fulfill the obligations imposed on them by the legislator in terms of training and education requirements.

The regulatory framework governing the issues of training is the Order of Rosfinmonitoring dated 03.08.2010 No. 203 “On Approval of the Regulation on Requirements for Training and Education personnel of organizations carrying out transactions with monetary funds or other property in order to counteract the legalization (laundering) of proceeds from crime and the financing of terrorism ”(colloquially referred to as“ 203 Rosfnmonitoring Order ”). According to the established tradition of the author, we will talk with you about the responsibilities in the field of financial monitoring not with quotations from regulations, which you can read on your own, without our help, but with your own in simple words, highlighting only the main and most important points.

First, let's decide who should receive targeted training on AML / CFT, raising the level of knowledge and other forms of training on financial monitoring in organizations and among entrepreneurs.

So, the following employees must undergo training on combating the legalization (laundering) of proceeds from crime and the financing of terrorism:

a) the head of the organization;

b) the head of the branch of the organization;

c) the deputy head of the organization (branch), in accordance with job responsibilities supervising the organization and implementation of internal control in order to counter the legalization (laundering) of proceeds from crime and the financing of terrorism;

d) a special official of the organization (branch) responsible for compliance with the rules of internal control in order to counter the legalization (laundering) of proceeds from crime and the financing of terrorism and programs for its implementation (in simple words - a special official);

e) Chief Accountant(accountant) of the organization (branch), if there is a position in the staff of the organization or branch, or an employee performing the functions of maintaining accounting;

f) the head of the legal department of the organization (branch) or the lawyer of the organization (if any);

g) employees of the internal control service of the organization (branch), if any;

h) other employees of the organization (branch) at the discretion of the head of the organization and taking into account the specifics of the activities of the organization (branch) and its clients.

Thus, it is easy to see that the circle of employees undergoing AML / CFT training is very wide and is not limited only to a special official, as many organizations and entrepreneurs think.

Most companies have at least general manager, chief accountant, lawyer, special officer for AML / CFT - all of them are required to undergo training in Rosfinmonitoring, incl. and targeted training in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

It is very important to note that the head of the organization must approve the list of employees who must undergo mandatory training and education on AML / CFT. This document is almost always requested by the employees of the supervisory authorities during the check, and at the same time they are asked to show them your staffing table. Staffing table they check not for the purpose of curiosity about the size of official salaries, as some readers might think, but to check whether all employees of your organization who are required to undergo training by law have completed it.

Let us now deal with the forms, frequency and timing of AML / CFT training.

Conditionally, training in the field of financial monitoring can be divided into two groups: external and internal.

To external forms of education We include targeted training on AML / CFT and raising the level of knowledge in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism.

To internal forms of learning on combating money laundering and terrorist financing include introductory and additional briefings.

External forms of training are carried out by specialized training centers that are partners of the International Training and Methodological Center for Financial Monitoring (ITMCFM), which was established by the Federal Service for Financial Monitoring. One of the well-known training centers providing targeted training on AML / CFT and raising the level of knowledge is the Interregional Training and Legal Consulting Center for Financial Monitoring (MUKPTSM), established by the author of this article and headed by his talented sister Serafima Aleksandrovna Smyslova. There are other training centers - partners of the ITMCFM.

What is targeted AML / CFT training? Target instruction is the acquisition by employees of organizations of the basic knowledge necessary for their compliance with the legislation of the Russian Federation on combating the legalization (laundering) of proceeds from crime and financing of terrorism, as well as the formation and improvement of the internal control system of organizations, programs for its implementation and other organizational administrative documents adopted for these purposes. It is this form of education that many organizations and entrepreneurs love so much: you come to a lecture and immerse yourself in interesting, exciting, important and useful knowledge (unless, of course, the lecturer of the training center is not some kind of bore, but an experienced and practicing AML / CFT specialist, teacher and real master their business). Someone remembers with longing the past student years with lectures from the institute, and for someone school desks and calls for recess. So, the whole day flies by imperceptibly, at the end of which the trainees write a test based on the results of the lesson and, in a solemn atmosphere, receive a certificate of completion of the targeted training in AML / CFT. The author of this article, after conducting targeted training on AML / CFT, always at the end of the seminar wishes the trainees health, happiness and all the best, productive application of the knowledge gained and work in the field of AML / CFT without fines. A good tradition has also been established in the MUKPSFM: at the end of the AML / CFT seminar, a common photo of the lecturer with the listeners of targeted training in the field of financial monitoring is taken as a souvenir.

Target instruction is given by trainees only once (once in a lifetime). It is important to note that training in the form of targeted briefing for a person planning to perform the functions of a special official takes place once before the start of such functions. One-time training in the form of targeted briefing must also be completed by: the head of the organization (branch), the chief accountant (accountant) of the organization (branch) (if there is a position in the organization's staff), or an employee performing accounting functions in the organization, the head of a legal department or a lawyer organizations (if there is a position in the organization's staff) - these employees must undergo a one-time training in the form of targeted instruction on AML / CFT within a year from the date of assignment of the relevant job responsibilities.

Not later than three years after passing the targeted briefing, the persons indicated in the previous paragraph are required to undergo the following form of external training - increasing the level of knowledge. Increasing the level of knowledge on AML / CFT is carried out in the form of participation in conferences, seminars and other training events, which is organized by training centers - partners of the IUMFCM and, in particular, the Interregional Training and Legal Consulting Center for Financial Monitoring (IUKFCFM). With this form of training, employees again sit down at their desks and listen to a fascinating story about their rights and obligations in the area of ​​AML / CFT. And again, some of the listeners recall their student youth, and some “wonderful school years”. And at the end of this important seminar on financial monitoring, if it was held at the IUKPFM, the author of this article in a solemn atmosphere presents the listener with certificates of increasing the level of knowledge.

We would like to note that some training centers convince trainees that they are obliged to undergo external training annually and literally fill up their clients with mailings with invitations to study and announcements of various AML / CFT seminars. Meanwhile, Order 203 of Rosfinmonitoring directly states that employees of organizations and entrepreneurs to whom this article is addressed are required to undergo advanced training in AML / CFT at least once every three years. Therefore, you are not required to attend training on financial monitoring, targeted training on AML / CFT, raising the level of knowledge for each invitation from the training center. Your frequent attendance at lectures is your right, but not your obligation. The author of this article recommends (but does not impose, as others do, his opinion) to undergo training in training centers about once a year - in order to always be in a “legal tone” and be aware of all the novelties of the rapidly changing AML / CFT legislation.

And if organizations and entrepreneurs are more or less able to cope with the obligation to undergo external training on combating money laundering (and they would not be able to cope when they are bombarded from all sides by training centers with their offers of targeted training services), then with internal forms of training (introductory and additional instruction on AML / CFT) everything is much more sad. The author of this article, being an AML / CFT consultant to many organizations and individual entrepreneurs, knows firsthand how internal training is stalled in them.

Introductory briefing in the organization is carried out by a special official when hiring for positions or to perform the functions indicated at the very beginning of our article. Let us remind you that this is a manager, a chief accountant, a lawyer, a special official, and other employees, i.e. all those whom the organization and the entrepreneur must include in the list of employees who must undergo training in accordance with the requirements of 203 of the Order of Rosfinmonitoring.

Introductory briefing is also carried out by a special official to employees and during their transfer (temporary transfer) to the above positions or to perform the above functions.

The same employees are also provided with additional training on AML / CFT by a special official. It is held at least once a year or at following cases:

When changing the existing and the entry into force of new regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism;

When the organization approves new or changes the existing rules of internal control in order to counteract the legalization (laundering) of proceeds from crime and the financing of terrorism and programs for its implementation;

When an employee of an organization is transferred to another permanent job (temporary job) within the organization in the event that his knowledge in the field of combating legalization (laundering) of proceeds from crime and financing of terrorism is insufficient to comply with the legislation of the Russian Federation on combating legalization (money laundering) ) proceeds from crime and financing of terrorism;

When instructing an employee to organize work performed by the above employees of the organization, but not due to the prisoner with him labor contract when the performance of such work does not entail a change in the terms of the employment contract concluded with the employee.

It should be noted that the introductory and additional briefings are carried out in accordance with the training and education program for the organization's employees in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism, developed by the organization taking into account the requirements of Rosfinmonitoring. The training program is very fond of checking the staff of the supervisory authorities. Recall that the training program in mandatory is part of the internal control rules for AML / CFT. But we also recommend approving the training program in the form of a separate document. Very often, organizations are faced with the requirements of auditors that it is not enough to have an AML / CFT training program only as part of internal control rules - it also needs to be approved as an independent document.

The developed training program should include:

a) study of the regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism;

b) the study of the rules and programs for the implementation of internal control in the organization in the performance of the employee's official duties, as well as the measures of responsibility that can be applied to the employee of the organization for failure to comply with the requirements of the regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime, and financing of terrorism and other organizational and administrative documents of the organization adopted for the purpose of organizing and exercising internal control;

c) study of typologies, typical schemes and methods of money laundering and terrorist financing, as well as criteria for identifying and signs of unusual transactions.

If, as a result of targeted instruction and raising the level of knowledge, students receive beautiful testimonies, which, as we have already mentioned, many people like to hang on the wall of their office, collecting a whole collection of them (we hope that if you nevertheless decide to collect testimonies, then all of them will be issued to you by our training center MUKPSFM), then how to record the facts of additional and introductory briefings with employees? To do this, we recommend that you keep two magazines: one for information about conducting an introductory briefing, the other for information about conducting an additional one. In them, you record the surnames, first names, patronymics and positions of the students, the dates of the briefings, the signatures of the employees about the briefing, and in the additional instruction log also the topic (reason) of the training. Do not forget that the special officer himself also conducts internal briefings. Even if you are the only one working in an organization: you are a director, an accountant, and a special official (a tailor, a carpenter, and a hunter for mice) - you still give yourself such briefings and make entries in journals.

It is very difficult to carry out additional instructions. If you hold it only once a year, then you are doing something wrong. Additional training in order to combat money laundering should be carried out much more often, because Regulatory legal acts of the Russian Federation in the field of combating the legalization (laundering) of proceeds from crime and the financing of terrorism are issued and changed very often (sometimes even several times a month). AML / CFT legislation changes so often that sometimes you cannot keep track of all of them. How not to get lost in a large array of legislation in the field of financial monitoring? Everything is very simple: the author of this article, on a voluntary basis, has been collecting all AML / CFT news on his website for many years in a row, incl. concerning the release of new or changes in the existing regulations on financial monitoring. The address of this site is known to many organizations and entrepreneurs: In 2016, the site celebrates its tenth anniversary since its foundation (we wish it many more years of work for the benefit of organizations and entrepreneurs and to popularize AML / CFT legislation). The author of the article also maintains a news block on AML / CFT in the popular social network In contact with. Here is the address of this group: https://vk.com/smyslovy The group is intended for communication on AML / CFT issues and contains hundreds of questions and answers on financial monitoring.

Follow the site, subscribe to news on https://vk.com/smyslovy and you will always be aware of what changes have occurred in the area of ​​AML / CFT.

We are often asked questions about additional instructions, approximately of the following nature: “we are a jewelry organization, the Federal Law of August 7, 2001 No. 115-FZ“ On Combating Legalization (Laundering) of Criminally Obtained Incomes and Financing of Terrorism ”has been amended concerning banks. Do we need additional instruction? " “It is necessary,” we answer: “After all, Order No. 203 of Rosfinmonitoring does not say anything about the need to take additional briefings selectively.”

The next popular question on completing additional training in the field of AML / CFT: “how many days are given to conduct training after approvals new edition internal control rules, the entry into force of amendments to the AML / CFT regulatory acts or the entry into force of a new regulatory act in this area? ”. "Not at all," we answer: "You are obliged to conduct the briefing on the day the rules are approved, on the day the normative act enters into force." We know of cases when a delay in instructing, even for several days, subsequently led to administrative punishment by the supervisory authorities.

1. Targeted training on AML / CFT and raising the level of knowledge You can take place both in the form of face-to-face seminars and in the online format (webinars on financial monitoring). However, in our opinion, full-time students learn the material much deeper, unlike webinar listeners. Therefore, try to take face-to-face seminars. The AML / CFT webinar is an option for those who live or work in remote regions and have no opportunity to come to the training center.

2. Seminars on financial monitoring (targeted instruction and raising the level of knowledge on AML / CFT), to which the training centers invite several lecturers during one day (the first lecturer leads the first two hours of the lesson, then the second, the third, etc.) - as a rule, it turns out to be very chaotic, without a clear sequence of presentation of the material, which negatively affects the quality of the lecture. Listeners run the risk of not hearing important material (because the first lecturer hopes that the second will complement it, and the second lecturer thinks that the first has already told everything). Sometimes lecturers contradict their positions during the day, which only confuses the audience.

3. Be sure to pay attention to the teaching staff of the training center. Sometimes seminars are conducted by lecturers who have only superficial knowledge in the field of AML / CFT, who do not know, for example, how to use personal account organizations on the Rosfinmonitoring portal have never submitted their reports to Rosfinmonitoring themselves; they acquired their knowledge by independently studying AML / CFT regulations or consulting their more experienced colleagues. One of best options lecturer is a practicing specialist in the field of financial monitoring who has gained his knowledge and experience in AML / CFT through many years of work with organizations and entrepreneurs, as well as himself vocational training as a specialist in educational activities in the field of AML / CFT.

This is what the certificate of a specialist in educational activities looks like

This is what a characteristic on a lecturer might look like.

4. Don't chase cheap targeted AML / CFT training. Prices for training and instruction in financial monitoring may differ even three or more times. It is quite obvious that if training is carried out very cheaply, it means that the training center saves on something (quite possibly on lecturers, inviting inexperienced specialists), which ultimately may negatively affect the quality of your training. You can get a certificate of completion of targeted instruction, but not get the most important thing - knowledge.

5. During the course of the AML / CFT seminar, try to take notes, highlighting the most important points for you. After completing the targeted briefing or raising the level of knowledge on AML / CFT, be sure to independently look at the regulations that the lecturer told you about.

6. Feel free to ask the lecturer questions. Giving answers to them is the direct responsibility of the lecturer. The AML / CFT workshop should go up to your last question.

7. There is an opinion that only industry-specific training is needed: ie. separate for jewelers, separate for real estate agencies, separate for leasing companies, etc. In reality, however, the AML / CFT legislation for all organizations is practically identical. An experienced AML / CFT lecturer and educator will conduct the seminar so that you will not experience any discomfort from the fact that, being, for example, a real estate agency, listened to the lecture as part of a group dominated by jewelers. An experienced lecturer will not deprive his attention of more than one scope of activity, whose representatives attend the training on combating money laundering and terrorist financing.

8. If you have been trained in AML / CFT, but you have not been told which reports are submitted to Rosfinmonitoring in what terms and how they are submitted, we recommend that you apply for retraining to another training center for financial monitoring. After all, the submission of reports - essential duty any organization and entrepreneur working in the field of AML / CFT. Ignorance of these issues is fraught with thousands of fines.

The high level of knowledge of the lecturer in matters of submitting reports to Rosfinmonitoring must be documented

9. Handouts (booklets, CDs, brochures on AML / CFT, etc.) that are supplied to you by some training centers tend to become outdated over time: legislation changes and documents in handouts become irrelevant. We recommend that you independently monitor all changes in the field of AML / CFT, being guided by the current legislation contained in various information and legal bases.

10. Carefully follow the name of the form of training that the training center writes for you in the certificate of training in AML / CFT. It so happens that the trainee needs to undergo an increase in the level of knowledge, and he was issued training as targeted instruction on AML / CFT. Or, conversely, the listener had to undergo a one-time targeted instruction in financial monitoring, and he was given a certificate of passing the knowledge improvement. It is very disappointing to receive comments on these facts later during the check.

11. If you have already completed targeted training on AML / CFT on behalf of one organization, then on behalf of another you do not need to undergo it, despite the fact that the name of your first organization is indicated in the training certificate: recall that the training certificate in the form of targeted instruction, it is named and contains your last name, first name and patronymic.

12. Lectures and seminars on AML / CFT by the author of this article, Pavel Aleksandrovich Smyslov, are very popular. Basically, he conducts them at the Interregional Training and Legal Consulting Center for Financial Monitoring. But he can also be seen in the composition of lecturers and other training centers- partners of ITMCFM Rosfinmonitoring: the students and the management of the training centers like the lecturer's simple and engaging way of talking about complex AML / CFT legislation. He travels a lot and conducts targeted training on AML / CFT throughout the country: from Crimea to the Far East.

We wish you a good completion of the targeted briefing, increase your knowledge in the field of AML / CFT! You can undergo targeted instruction from the author of this article by signing up for training at this link:

Financial Monitoring Expert, Ph.D. history. Sci., lawyer Pavel Smyslov

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Procedure upon receipt of a request from the Prosecutor's Office:

1. Carefully study the list of required documents;
2. Check the internal control rules for AML / CFT purposes for compliance with applicable law at the time of submission to the Prosecutor's Office;
3. Check with the assistant prosecutor what is meant by this or that document if the requirement contains vague wording;
4. Examine all the responsibilities of organizations or individual entrepreneurs that must be performed in accordance with the law in order to answer all the questions of the inspector;
5. If you doubt the correctness of the organization of internal control, in accordance with the documents with the norms of legislation, contact a specialist in financial monitoring and AML / CFT.

Specialists of the "National Treasure" (MCFM) participated in numerous checks carried out by the Prosecutor's Office, and know all the subtleties of this process.

When contacting the center, a specialist:

• analyze all available documents in the organization or at the individual entrepreneur;
• if necessary, correct the mistakes made;
• prepare missing documents;
• will conduct a detailed consultation on the procedure for checking documents by the Prosecutor's Office;
• prepare the responsible employee or manager for the typical questions that the inspector may ask;
• if necessary, our specialist can be present with you in the Prosecutor's Office when providing documents by power of attorney or provide your interests on his own.

Typical mistakes made by organizations and individual entrepreneurs when checking the Prosecutor's Office.

• provision of an incomplete package of documents due to misunderstanding of the wording set out in the requirement.

The same applies to the common misconception that if the organization has no employees other than the director or individual entrepreneur, then there is no need to draw up training documents;

• lack of knowledge of the responsibilities of the organization or individual entrepreneur in financial monitoring and AML / CFT leads to the fact that, when interviewing the supervisor and the responsible officer, the latter cannot answer the questions correctly about the procedure for performing duties.

• provision of internal control rules for AML / CFT purposes in the version not up to date as of the date of submission.

We have described only some of the errors. If you are not 100% sure that you are correctly and fully complying with the requirements of the law, first contact the professionals.

Our specialists have developed a package of documents for non-bank financial institutions in accordance with the requirements of the Ordinance of the Bank of Russia dated December 5, 2014 No. 3471-U "On the requirements for training and education of personnel in non-bank financial institutions":

1. Training and education program for employees in the field of AML / CFT / FROMU.
2. Training program for employees on AML / CFT / FROMU for conducting introductory (primary) briefing.
3. Certificate of employee training in AML / CFT / FROMU.
4. Attestation sheet.
5. Tests for checking employees' knowledge of AML / CFT / FROMU (25 pieces).
6. Answers to tests (25 pieces).
7. Annual plan for checking the knowledge of employees on AML / CFT / FROMU.
8. Annual plan for the implementation of the training program for employees on AML / CFT / FROMU.
9. Order on approval of the list of employees who must undergo mandatory training and education in AML / CFT / FROMU.

An example of a training and education program for employees of a non-bank financial institution on AML / CFT / FROMU, drawn up by our specialists

For an additional fee, our specialists prepare all of the above documents, taking into account organizational structure non-credit financial organization and its type of activity (pawnshop, MCC, MFC, KPC, SKPK, insurance company, insurance broker, NPF, MC, etc.). Upon receipt of documents by e-mail, you will only have to print, sign and seal them. Service details by e-mail [email protected] site/

Training and education program for employees of a financial institution in the field of AML / CFT / FROMU

A financial organization with the nature and characteristics of its activities, the nature and characteristics of the activities of its clients should take measures aimed at training and education of its employees on AML / CFT. So, first of all, a financial institution should develop a program for training and education of employees in the field of AML / CFT and a list of employees who must undergo AML / CFT training approved by the head of the financial institution. At the same time, the training program for NFI employees on AML / CFT must necessarily contain:

• study of legislative acts of the Russian Federation, regulations of the Bank of Russia and other regulations of the Russian Federation in the field of AML / CFT;
• study of the rules and programs for the implementation of internal control in a financial organization in the performance of an employee of official duties, as well as measures of responsibility that can be applied to an employee of a financial organization for failure to comply with legislative acts of the Russian Federation, regulations of the Bank of Russia, other regulations of the Russian Federation in the field of AML / FT and internal documents of a financial organization adopted for the organization and implementation of internal control;
• study of typologies, typical schemes and methods of money laundering and terrorist financing, as well as criteria for identifying and signs of unusual transactions;
• checking the knowledge of the financial institution's employees on AML / CFT.

The AML / CFT training and education program should be reviewed periodically (at least once a year) by the responsible officer. That is, for example, a special official is obliged to update tests annually in order to test the knowledge of employees of a financial organization, to update educational and methodological material intended for conducting an introductory briefing with employees when they are hired.

The initial examination of the knowledge of the financial institution's employees on AML / CFT is carried out after one month from the date of the induction (primary) briefing. The form and procedure for testing the knowledge of employees on AML / CFT are determined by the financial institution independently. For example, it can be testing employees.

In addition to taking into account the facts of checking the knowledge of employees, it is also necessary to keep records of employees' training in three forms. The procedure for maintaining such records is established by the head of the financial organization. The fact of conducting an introductory (primary) and targeted (unscheduled) briefing with an employee must be confirmed by his handwritten signature in a document, the form and content of which the financial institution establishes on its own. Documents (or their copies) confirming the employee's AML / CFT training are stored in the employee's personal file during the entire time of his work in a financial organization. It is allowed to store these documents in in electronic format... Recall that training in financial institutions is carried out in three forms:

1. introductory (primary) briefing;
2. targeted (unscheduled) briefing;
3. advanced training (scheduled instruction).

Introductory briefing for employees of a non-bank financial institution

Introductory (primary) briefing is carried out in order to familiarize employees with the legislative acts of the Russian Federation, regulations The Bank of Russia, regulatory legal and other acts of the Russian Federation in the field of AML / CFT, as well as internal AML / CFT documents of a financial institution. Internal AML / CFT documents primarily include internal control rules or, for short, they are referred to as the AML / CFT ICR.

The introductory (primary) briefing is carried out once by the responsible employee within one month from the day the employee is hired, as well as from the day of transfer to other positions.

Targeted briefing of employees of a non-bank financial institution

Employees of a financial institution undergo targeted (unscheduled) briefings in order to acquire the knowledge necessary for their compliance with legislative acts of the Russian Federation, regulations of the Bank of Russia, regulatory legal and other acts of the Russian Federation in the field of AML / CFT, as well as the formation and improvement of the system of internal control of non-credit financial institutions, programs for its implementation and internal documents of a non-bank financial institution adopted for AML / CFT purposes. Training in the form of targeted (unscheduled) instruction should be completed by:

• a person planning to exercise the functions of a responsible official, prior to the commencement of such functions;
• the head of a financial institution and the head of a branch of a financial institution, prior to appointment to the relevant position;
• an individual entrepreneur who is an insurance broker, prior to the commencement of activities to provide insurance broker services;
• employees of the AML / CFT structural unit, employees of the internal control service of a financial organization (including a branch) and employees from additional lists established by the Bank of Russia, within a year from the date of appointment to the relevant positions or assignment to them of the relevant official duties.

Targeted (unscheduled) briefing of the employees of the financial institution specified in this Directive is carried out by the responsible employee in four cases:

1. upon amendments to the current legislation and the entry into force of new legislative acts of the Russian Federation, regulatory acts of the Bank of Russia, regulatory legal and other acts of the Russian Federation in the field of AML / CFT, in terms of issues related to the relevant areas of activity of financial organizations, no later than three working days from the date the entry into force of the relevant acts;
2. when a financial institution approves new or changes in the existing internal control rules for AML / CFT purposes and programs for its implementation, no later than ten business days from the date of approval or amendment of these documents. At the same time, for persons subject to training in accordance with the requirements of this Directive and who are absent from the workplace due to vacation, business trip or temporary disability, the period begins to be calculated from the working day following the day of the end of the vacation, business trip or a period of temporary disability.
3. when an employee is transferred to another permanent job (temporary job) within a financial institution, providing for the performance of functions different from those performed by him before such transfer, in the case when, in order to ensure compliance with the AML / CFT legislation of the Russian Federation, when the employee performs new functions, it is required to carry out a targeted (unscheduled) briefing - no later than ten working days from the date of the occurrence of the relevant event;
4. when instructing an employee of a financial organization to work performed by employees of a financial organization specified in the additional lists of the Central Bank, and not stipulated by an employment contract concluded with him, when the performance of such work does not entail a change in the terms of such an agreement - no later than ten working days from the date of the occurrence of the relevant case ...

Professional development of employees of a non-bank financial institution

Further training (scheduled instruction) is carried out in the form of participation in seminars and other training events.

Responsible employees of financial institutions undergo advanced training (scheduled instruction) at least once a calendar year.

Employees of insurance organizations and professional participants in the securities market included in the list undergo advanced training (scheduled instruction) at least once a calendar year.

Other employees of financial institutions included in the List undergo advanced training (scheduled instruction) at least once every two calendar years.

The main (general) list of employees of a financial institution who must undergo training in AML / CFT

In Ordinance No. 3471-U of 05.12.2014 "On the requirements for training and education of personnel in non-bank financial institutions", the Bank of Russia established general and additional lists of NFI employees who are required to undergo AML / CFT training. So, the following employees are included in the main list, respectively, if there are appropriate positions in the staff:

1. the head of a financial organization;
2. branch manager of a financial institution;
3. the deputy head of a financial institution (branch) in charge of the organization and implementation of internal control for AML / CFT purposes in accordance with the written distribution of responsibilities;
4. chief accountant (accountant) of a financial organization (branch) or an employee performing accounting functions;
5. a special official responsible for the implementation of internal control rules for AML / CFT purposes in a financial institution;
6. employees of the AML / CFT structural unit, if such a structural unit is formed under the leadership of a responsible officer;
7. controller;
8. employees of the internal control service of a financial organization (branch);
9. the head of the legal department of a financial organization (branch) or a lawyer;
10. the head of the security service of a financial institution (branch);
11. other employees of a financial organization (branch) at the discretion of its head, taking into account the specifics of the organization (branch) and the activities of its clients.

Additional lists of financial institution employees who must undergo AML / CFT training

In addition to the general list of positions of employees who must undergo training in AML / CFT, the Bank of Russia in Ordinance 3471-U established additional lists of employees depending on the type of activity of the financial institution.

1. A professional participant in the securities market,

1. head and deputy head of the structural unit of a professional participant in the securities market (branch), which carries out professional activities in the financial market;
2. employees of a professional participant in the securities market (branch) who, in accordance with their job responsibilities, perform at least one of the following functions:

• • execution of transactions with securities, including on behalf of a professional participant in the securities market and at the expense of a professional participant in the securities market, on behalf of clients and at the expense of clients, on behalf of a professional participant in the securities market and at the expense of clients;
  • maintaining internal records of transactions with securities;
  • carrying out operations related to the transfer of ownership of securities on clients' securities accounts;
  • carrying out operations related to the transfer of ownership of securities through the personal accounts of registered persons.

2. Management company the additional List includes the following employees:

1. head and deputy head of the structural unit management company(branch) that operates in the financial market;
2. employees of the management company (branch) who, in accordance with their job responsibilities, perform at least one of the following functions:

• • execution of transactions and (or) operations with monetary funds and (or) securities in the interests of the founder of the management;
  • signing of outgoing documents of the management company (branch) concerning the implementation of operations related to the management of mortgage coverage;
  • signing of outgoing documents of the management company (branch) concerning the implementation of operations related to the management of investment reserves of a joint-stock investment fund, property constituting a mutual investment fund, pension reserves of a non-state pension fund or property in which pension savings or savings are invested for housing provision of military personnel ;
  • signing of outgoing documents of the management company (branch) relating to the implementation of operations related to the management of securities belonging to a joint-stock investment fund, securities within the property constituting a mutual investment fund, or securities in which the funds of the pension reserves of a non-state pension fund are placed or invested retirement savings or savings for housing for military personnel.

3. Insurance organization the complementary list includes the following employees:

1. head and deputy head of a structural unit of an insurance organization (branch) performing functions related to insurance activities;
2. employees of the internal audit service of the insurance organization (branch);
3. employees of an insurance organization (branch) who, in accordance with their job responsibilities, perform at least one of the following functions:

• • conclusion of insurance contracts;
  • execution of transactions and (or) operations with insurance reserves and (or) own funds(capital).

4. NPF the complementary list includes the following employees:

1. head and deputy head of the structural unit of the NPF (branch), which operates in the financial market;
2. NPF (branch) employees who, in accordance with their job responsibilities, perform at least one of the following functions:

• • making transactions and (or) operations with pension reserves and (or) pension savings;
  • performing operations on payment and (or) transfer of funds for non-state pension provision, including early non-state pension provision, compulsory pension insurance.

5. CPC, including CCCC, and MFIs (MCC and IFC) the additional list includes employees performing functions of raising funds from individuals and legal entities.

An additional list of employees is not currently established only for pawnshops. For other financial institutions, the Bank of Russia has established lists for each type of activity.

1.- yes, I must,

2.- up to 30 days

How often does a customer service officer need to update customer identification information?

Answer:

In all these cases
How does a customer service officer guide you when a transaction is classified as unusual?

Answer:

A set of criteria for suspicion, characteristics of the client, the employee's suspicions about the possible legalization of income, regardless of the amount of the transaction
Does the customer service officer need to identify and examine the persons being served?

Answer:

Yes, when performing all banking operations and other transactions in excess of the amount established by the legislation of the Russian Federation
What sanctions by supervisory authorities can be applied to a credit institution for violations of the Federal AML / CFT Law?

Answer:

Administrative suspension of activities

Administrative penalty

License revocation
The client purchases a certificate of deposit from a credit institution in the amount of 1 million rubles. Is this operation subject to mandatory control?

Answer:

Yes, in any case, by opcode 4006
Which of the listed types of transactions with movable property for an amount in excess of the established value criterion correspond to Operation Group Code 50?

Answer:

Receipt or provision of property under a financial lease (leasing) agreement

Purchase and sale of precious metals in physical form and in impersonal form, purchase and sale of coins made of precious metals

Provision by legal entities that are not credit institutions, interest-free loans to individuals and (or) other legal entities, as well as obtaining such a loan
What rate is used to determine the ruble equivalent of the transaction amount indicated in the amount of precious metal or in foreign currency for transactions with precious metals or transactions with foreign currency in cash?

Answer:

The rate set by the Sberbank of Russia

Answer:

All listed documents
Who makes the decision to recognize the client's transaction as a transaction subject to suspension?

Answer:

Relevant Bank Controller
Which of the listed types of transactions with real estate for an amount in excess of the established cost criterion correspond to the code of the type of operation 8001?

Answer:

All real estate transactions
An employee of the customer service department revealed that funds were credited (debited) in the amount of 650,000 rubles on the account legal entity, operations on which have not been performed since its opening. Should an employee consider this operation as an operation subject to mandatory control?

Answer:

Yes should
For how long is the suspension of the operation carried out if at least one of the parties is an organization or an individual in respect of which there is information received in the prescribed manner about their participation in terrorist activities?

Conducting transactions with precious metals
What documents does an employee of the customer service department request from a legal entity when it opens a current account, as part of identification?

Answer:

Client information.

How many times does a customer service employee need to receive training on AML / CFT issues?

Answer:

At least once a year
What measures are not taken in the process of suspending an operation if at least one of the parties is an organization or an individual in respect of which there is information received in the prescribed manner about their participation in terrorist activities?

Answer:

After the decision to suspend the operation, the employees of the customer service department inform the Client about the reasons for the suspension of the operation
If an employee of the customer service department has established that the operation carried out by the client is subject to mandatory control, when should he send a message on the operation to the Controller?

Answer:

Not later than 10:00 on the business day following the day of the transaction
What documents are the basis for identifying beneficiaries?

Answer:

All listed contracts
How is a customer service employee guided when detecting extremist or terrorism-related transactions?

Answer:

A list containing information about persons involved in extremist activity or terrorism, regardless of the amount and nature of the operation
Which of the following structures are supervisory bodies for a credit institution on AML / CFT issues:

Answer:

1) Bank of Russia;

3) federal Service financial monitoring;

4) The Prosecutor's Office of the Russian Federation;
What type of transaction code is assigned to a dubious transaction carried out within the framework of large cash “cashing out” schemes and capital withdrawal abroad?

Answer:

Code 6001 - Suspicious Operation
What is a customer service employee guided by when identifying transactions that are subject to mandatory control?

Answer:

The coincidence of the cost criterion and the type of operation
An employee of the customer service department became aware of the implementation of a transaction with real estate by the client in the amount of 2.5 million rubles. Is this operation subject to mandatory control?

Answer:

No, since the transaction amount does not exceed RUB 3,000,000
Which of the following must be established in the process of conducting the procedure for identifying a client of a legal entity?

Answer:

1) full and abbreviated name;

2) information about state registration;

4) address of location and postal address;

6) contact telephone and fax numbers.

1. What are the actions of an employee of the customer service department when detecting an operation of crediting to the Client's account in the amount of 100,000 rubles, where one of the parties is an individual who is on the List containing information about persons involved in extremist activities or terrorism?

The amount of the transaction is less than 600,000 rubles, so it is not subject to mandatory control

Operations for crediting funds to the account are not subject to mandatory control.

- The employee sends a message to the Controller with the code 7001

No correct answer provided

The employee sends a message to the Controller with a sign of suspiciousness under code 6001
2. What information must be established in the process of carrying out the procedure for simplified identification of a client of an individual?

Full Name

No correct answer provided

- Full Name; details of the identity document

Full Name; Date and place of birth; citizenship; details of the identity document; TIN; data of insurance certificate of state pension insurance data of migration card and document confirming the right to stay in the Russian Federation (for a foreign citizen or stateless person)

Full Name; Date and place of birth; citizenship; details of the identity document; data of a migration card and a document confirming the right to stay in the Russian Federation (for a foreign citizen or stateless person)
3. What documents should be followed by an employee of the customer service department in fulfilling his duties in the field of AML / CFT?

Federal Law No. 115-FZ and the Rules of the Security Council of the Russian Federation No. 881-5-r

- All specified documents

Technological scheme of VVB SB RF No. 244-4-VVB

Rules of the Security Council of the Russian Federation No. 881-5-r and the Order of the VVB of the Security Service of the Russian Federation No. 244-4-vbb

Federal Law No. 115-FZ, Rules of the Security Council of the Russian Federation No. 881-5-r, as well as regulatory documents Bank of Russia (Regulation of the Central Bank of the Russian Federation No. 321-P, Regulation of the Central Bank of the Russian Federation No. 262-P, etc.)
4. How does an employee of the customer service department assess the degree (level) of the risk of money laundering and terrorist financing?

Uses criteria set by the account manager

Requests data on the degree of risk from the client

In the case of the client's first contact, indicates that the degree of risk is absent

An increased degree of risk is established only for transactions that are subject to mandatory control

In all of the above ways.

- Uses the signs established by the Rules No. 881-5-r of 12.05.10
5. Which of the specified information is requested by an employee of the customer service department from an individual when identifying him / her?

Nationality

Data of insurance certificate of state pension insurance

All listed information

Data of a migration card and a document confirming the right of a foreign citizen or stateless person to stay (reside) in the Russian Federation with a client who is a foreign citizen or stateless person

- Details of the identity document

6. Who is to be identified, if the client has given the authority to manage the bank account (deposit), also to another person?

Identification in this case is not carried out

- Both the client and the person who has been given the authority to manage the bank account (deposit)

The person who has been empowered to manage the bank account (deposit)
7. What is guided by an employee of the customer service department when determining a transaction as dubious, associated with the “cashing out” of large funds and the withdrawal of capital abroad?

- Signs of the implementation of dubious schemes for "cashing out" and the withdrawal of capital abroad

The coincidence of the cost criterion and the type of operation

Type of operation

Cost criterion

The coincidence of the cost criterion and the type of operation, as well as the frequency of transactions
8. Is it checked in the process of identifying a counterparty of the Bank its presence in the list containing information about persons involved in extremist activities or terrorism?

- Yes, anyway

No, since transactions with counterparties do not apply to transactions or transactions specified in Article 5 of the Federal Law dated 02.12.1990 No. 395-1 "On Banks and Banking Activities"

No correct answer provided

No anyway

Yes, if the transaction performed with the counterparty is subject to mandatory control
9. For how long is the operation suspended if at least one of the parties is an organization or an individual in respect of which there is information received in the prescribed manner about their participation in terrorist activities?

The period for which the operation is suspended is set at the discretion of the Head of Customer Relations

The period for which the transaction is suspended is at the discretion of the relevant Controller.

The period for which the operation is suspended is set at the discretion Authorized body

- For two working days from the date when the client's order on its implementation must be executed, if the operation is not suspended for an additional period by a resolution of the Authorized Body

For five working days from the date when the client's order on its implementation must be executed, if the operation is not suspended for an additional period by a resolution of the Authorized Body
10. What is prohibited for an employee of the customer service department when implementing AML / CFT measures?