Alfa Bank AntiMoney Laundering

1
Alfa Bank Anti-Money Laundering
2
Alfa Bank Anti-Money Laundering
Relevant Federal Laws CBR Regulations
 Date Regulations 3 July 1997 CBR Letter ? 479
On methodic recommendations on the issues of
organizing work organizations .  ? No real
regulation yet a FATF manual rip off. Somebody
in the Government probably said You guys better
start doing something on this anti-money
laundering stuff 12 February 1999 CBR Directive
? 500-? On reinforcement of currency exchange
regulation from the part of authorized banks
over the relevance of the currency operations
performed by their clients and on the
procedure of using influence measures upon the
authorized banks for the braches of currency
legislation. 15 March 2001 CBR Letter ? 24-?
On Volfsberg principles.for prevention of
penetration of illegal means to the banks and
other credit  ? Getting close, but not really
there yet. Look how they do it in the good ole
West.
3
Alfa Bank Anti-Money Laundering
Relevant Federal Laws CBR Regulations
Date Regulations 7 August 2001 Federal Law ?
115 - ?? On methods aimed at Anti-Money
Laundering of criminally received money.  ?
There you have it, folks. The Law. Thou shalt not
launder money. Sets the general rules of the game
and points a finger at CBR.   23 November
2001 CBR Regulation ? 160-? On the order of CBR
performing control over executing by the
credit organizations of the Federal Law
Methods aimed at Anti- Money Laundering of
criminally received money.   23 November
2001 CBR Regulation ? 161-? (On the order of
lending agencies' presenting to authorized
organs data regarding Federal Law Methods
aimed at anti laundering of criminally
received money
4
Alfa Bank Anti-Money Laundering
Relevant Federal Laws CBR Regulations
Date Regulations 23 November 2001 CBR
Directive ? 137-? On recommendation for lending
organs to work out Internal Control Rules
aimed at anti laundering of criminally
received money of 28.11.2001.   ? The real
stuff. The works. No money laundering after this
set of rules, please. Makes us report every
trade with off-shore-looking jurisdiction on it
and in excess of 20K. Gives detailed
description of what we have to report now and
will have to report in the future. However, no
official list of suspicious jurisdictions has
been released so far until we got this list, we
had no idea what to report
5
Alfa Bank Anti-Money Laundering
Relevant Alfa Bank Actions
Date Alfa Bank Action   April 2000 Alfa
Securities, London, puts in place Money
Laundering Procedure in compliance with SFA
requirements June 2000 Alfa Securities receives
SFA approval and was given licence. February
2001 Alfa Securities prepares for SFA Field
Audit, video materials reviewed and procedure
tightened
6
Alfa Bank Anti-Money Laundering
Relevant Alfa Bank Actions
Date Alfa Bank Action   March-April 2001 Alfa
Bank, Moscow, proposes plan of measures on Money
Laundering procedure (Executive summary),
Vetting Policy, translates London materials
contacts US Treasury for guidance received
Materials on International cooperation in
Anti-Money Laundering - US Department of
Justice RF General Office of Public
Prosecutor issued in St.-Petersburg, 2000 April
2001 Alfa Bank contacts IT in correspondent
banks in US, first screening software 4 April
2001 Prikaz 180 on Money Laundering Policy 28
April 2001 Letter to existing clients of Bank and
Prikaz 230, control measures and forms
7
Alfa Bank Anti-Money Laundering
Relevant Alfa Bank Actions
Date Alfa Bank Action 17 May 2001 Computer
payment filtering system launched 31 May
2001 Prikaz 265 formal response to Money
Laundering, setting up authorised forms 6 June
2001 Prikaz 280 listing suspect governments and
territories 19 June 2001 Prikaz 293 organising
and empowering Working Group on Money
Laundering 28 June 2001 Prikaz 308 changing
measures and formalising different forms to Pr.
230 3 July 2001 Prikaz 318 formalising new
measures 10 July 2001 Prikaz 330 on new Money
Laundering Policy 20 December 2001 Computer
payment screening system Version II 27 December
2001 Prikaz 588 on role of Internal Control 31
January 2002 Prikaz 42 nominating Money
Laundering Officer to report on compliance with
Federal Law 115