We must all know what money laundering is. Even if we don't know it, we have seen it on TV. In China, money laundering is an illegal and criminal act, which will seriously endanger the country's economic security. Money laundering is a common act of a team, not one person. So what does the anti money laundering double punishment system mean?
Punishment measures and preventive measures of anti money laundering double punishment system
With the fourth round of FATF mutual evaluation approaching, the people's Bank of China and its branches (hereinafter referred to as the "people's Bank") have strengthened the punishment for anti money laundering violations. In 2017, the people's Bank of China published more than 350 anti money laundering punishment records, with a total punishment amount of nearly 90 million yuan.
Among the anti money laundering penalties in 2017, the penalties for the obligatory units and relevant responsible persons ('double penalty system ') accounted for 73% of the total penalties. Some people's banks put the penalties against the obligatory units and relevant responsible persons in the same punishment record, while others list them in different punishment records. Only a few units or individuals were punished, accounting for 26% and 1% of the total punishment respectively. Therefore, 'double punishment system' has become the main way of punishment.
In the punishment of publishing specific illegal acts, more than 90% of the punishment involves failing to perform the customer identification obligations as required; Nearly half of the penalties involved failure to perform suspicious transaction reporting obligations and failure to perform large value transaction reporting obligations as required; Nearly one fifth of the penalties involve failure to fulfill the obligation of keeping transaction records and the obligation of keeping customer identity data. " Other illegal acts mainly include trading with unidentified customers or opening anonymous accounts or pseudonymous accounts for customers.
In recent years, the regulatory requirements have been continuously improved and the punishment has been strengthened. In order to better cope with these changes, all voluntary agencies should focus on improving the current work situation and making good use of science and technology.
Taking the customer identification work that regulators attach great importance to as an example, more than 90% of the penalties are for illegal acts, including 'failing to perform the customer identification obligations as required'; In the classification and rating of anti money laundering, the score related to customer identification is close to 20 points (out of 100 points); The automatic tax related information exchange standard for financial accounts ('crs') also puts forward corresponding requirements for customer identification. With the launch of the notice of the people's Bank of China on strengthening the work related to anti money laundering customer identification ('Document No. 235 '), the requirements of regulators for customer identification have been further improved: it is not only necessary to strengthen the identification of non natural person customer benefit owners and specific natural persons, but also need to pay attention to the identification measures of customers in specific business relationships.
It is difficult for each obligatory institution to only rely on the original anti money laundering compliance system to meet the latest regulatory requirements, which needs to be realized by supplementing the anti money laundering system and improving customer information collection. PwC can design corresponding customer identification schemes for different types of customers, establish a list of document requirements and a list of problems, and provide corresponding disposal suggestions for unidentified customers by sorting out the customer types of each obligation institution and the current situation of anti money laundering work; At the same time, adjust the organizational structure as needed.
On the other hand, with the increase of customer scale and transaction volume of various voluntary institutions, it is more difficult to complete customer identification only manually. At the same time, there are a lot of work that can be completed by robots in customer identification, such as customer identification progress monitoring and data submission, blacklist update, regular scanning of customer risk elements and prompt risks, non natural person customer information retrieval, etc. PwC can provide corresponding technical solutions in these aspects, which can greatly improve the company's risk management ability and resource utilization efficiency.
According to the above contents, we can find that the people's Bank of China has strengthened the control of the anti money laundering double punishment system, generally punishes money laundering by means of fines, provides different disposal suggestions for different types of customers, strengthens supervision at the source, innovates in science and technology, pays attention to the identity information of customers in business, and takes timely measures once found, We should also be vigilant in life.