- AML Policy and Compliance (see example below)

- What is Money Laundering?

Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities. If undertaken successfully, it allows criminals to control these funds, which are converted from "dirty" to "clean".

- the Suspicious Transaction Guidelines (Anti-Money Laundering Guidelines) issued by the Financial Intelligence Unit, January 2001?
Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activities. If undertaken successfully. it also allows them to maintain contro1 over these proceeds and, ultimate1y, provide a legitimate cover for the source of their income. Examples of the crimes which can result in money laundering, are drug trafficking, theft and fraud, terrorist activity, robbery, forgery and counterfeiting, illegal deposit taking, blackmail and extortion.

- Compliance
Compliance Department has the responsibility for owning and co-coordinating the creation and maintenance of policies and procedures and for the steps Winterbotham should take to meet its legal obligations in respect of money laundering prevention. Compliance also has specific responsibilities for ensuring that business units/operations introduce controls and procedures relating to customer identification, record keeping and staff education and training. Overseeing the introduction of controls and procedures by the business /operation unit relating to the reporting of suspicious transactions is the joint responsibility of Compliance and Senior Management

- The Three Stages of Money Laundering
Despite the variety of methods employed, the laundering process is accomplished in three main stages, which may comprise numerous transactions.
Placement Stage e.g. cash paid into a bank account, often the funds are mixed with the proceeds of a legitimate business.
Layering Stage e.g. domestic or international money transfers to other accounts, often using shell companies or fictitious invoices to justify the payments.
Integration Stage e.g. proceeds used to buy assets, such as cars, houses, stock exchange securities.