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V INTERNATIONAL CONFERENCE ANTI-MONEY LAUNDERING AND AGAINST THE FINANCING OF TERRORISM
JULY 15 AND 16, 2009
EUROBUILDING HOTEL , CARACAS - VENEZUELA



Conclusions and Recommendations from theV International Conference: Anti-money Laundering and against the financing of Terrorism at the Eurobuilding Hotel in Caracas July 2009. The global financial crisis left the pieces of a financial system that before

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1.  Organized crime has extended stealthily its strings to get to the financial sector most emblematic structures, strings that make their own way before the regulators eyes and that became visible once the financial crisis exploded.

2. Criminal organizations are facing this crisis not as a problematic but as a chance to make of the financial system its hideout, a permanent and personalized washer machine, taking advantage of the owners concern for keeping their business on float.

3. Check the application of new figures inside financial institutions, besides money laundering preventive units, that allow improve the implementation of high quality reports so these can go to the pertinent institutions such as FIU, Bank Superintendence.

4. It is probed that money laundering besides from be originated of the commission of another crimes such as drug trafficking, It is also probed that it does not distinguish the sector to be  used for this proposes, this means that trade o insurance sector as well as real sector can not be dismissed.

5. All companies and business must pay attention and study closely their providers, clients and the zone these are located (geostrategic risk). This previous study of the client and/or provider will give clues of futures red flags that can become finally in a risk to be involved in a money laundering web.

6. Money laundering prevention does not mean interrupt the business area work inside financial institutions; it only means establish measures that allow to the bank personnel to be aware of clients; to know the costumer is an advantage that in long term allow the bank if this client is related to money laundering rings, it also provide tools to offer them product according to their necessities.

7. Anti-money laundering measures and policies are closely related to the authority figure inside financial institutions. The compromise of a high range executive with the financial institution allows this AML policies implement correctly leaving optimums results. This does not means they cannot be implemented without this figure, but the result will not be the most efficient.

8. The client recognizes that financial crimes such as fraud, money laundering, terrorism financing and others, do not distinguish among social classes. Equally money launders or pyramid schemes creators can be seen as prestige lords when in fact they count with the client’s ignorance to performed their scams.

9. Worldwide corruption is increasing with the financial crisis deepening. The range goes further financial sector, open itself way to daily activities. Corruption besides has become in the last decade in a support system for money launders who can be former presidents or another governmental officials, drug dealers, etc.

10. Hierarchical figures inside financial institutions must be aware to the client´s and provider´s behave as well, they also must pay attention to their employees when they get new clients.

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1. Foment the evolution of compliance officer function given the conditions and current development of the financial system and the organized crime inside this.

2. Support initiatives of international organizations such as UN programs and workshops for judge, district attorney and agents training in money laundering prevention.

3. Foment educational campaigns on Money laundering that include society in order they can identify too when an inversion can be fraudulent or not. This initiative must base on the principal “educate to prevent”.

4. Face governmental measures throughout reforming laws that can derive in a violation of impartial and optimums of anti-money laundering functions and policies inside financial institutions. In this particular case, it occurs in Venezuela, where the government wants to implement an “control agent” (agente de control) inside financial institutions. This figure could mean a measure that could affect the generation of positive results, besides distrust among clients for different reasons.

5. Evaluate the risks to which financial institutions are exposing in Latin-America through the pertinent systems to know deep where these plans against money laundering and terrorism financing are going. To do so areas inside these entities must cooperate between each other and be also willing to engage, working as one.

6. Check as supervisors or regulatory agent that clients classified as PPE, are include as such in this category and not make omission of their condition. On contrary, a better diligence must be implemented in this matter, with them, their relatives and associates, avoiding corruption rings in governments.

7. Carry out inside financial institutions about the implementation of systems such as SARLAFT, only then it will be avoid the implementation of different rules in manuals or documents about how systems like SARLAFT are supposed to work. Likely is important that banks adjust to SARLAFT and its characteristics rulling out generalities to prevent its miss function and critics from future evaluations that end up with very severe sanctions.   

8. Check initiatives implemented in other countries, such as the implementation of FIU inside every financial institution, structure that today is used in about 50 banking entities in the United States. Off course every nation represents a different model, meaning this measure must be studied according to every case.



       
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