Core idea

Financial crime compliance starts with understanding the financial system. Banks provide deposit, lending, payment, trade, foreign exchange, and settlement services. Each product can be misused for placement, layering, integration, fraud, sanctions evasion, bribery, terrorist financing, or other financial crime risks.

Key takeaways

• Banks move value through accounts, payments, credit products, trade products, and settlement channels.
• FCC risk is connected to ordinary customer activity, not only visibly suspicious transactions.
• Governance, controls, escalation, and documentation are needed to manage product and customer risk.

Terms to remember

Settlement System

The infrastructure and process used to complete payment obligations between parties or institutions.

FCC Governance

The control framework, roles, policies, escalation paths, and oversight used to manage financial crime risk.

Core idea

Different account types create different expected behaviours. Personal, corporate, non-resident, foreign currency, dormant, unclaimed, and high-volume accounts need different controls because the customer purpose, transaction pattern, documentation, and risk profile differ.

Key takeaways

• Account purpose and customer profile are the baseline for monitoring.
• Dormant, unclaimed, high-volume, non-resident, and foreign-currency accounts can create specific red flags.
• Modus operandi analysis links account behaviour with financial crime typologies.

Core idea

AML/CFT work connects financial crime theory with daily control activity. Money laundering commonly involves placement, layering, and integration. Terrorist financing can use legitimate or illegitimate funds, but the intended use is the central risk. Monitoring and reporting processes convert red flags into structured investigation decisions.

Key takeaways

• AML and CFT are related but not identical.
• Transaction monitoring compares observed activity against customer profile and expected behaviour.
• CTR, STR, and SAR serve different regulatory and intelligence purposes.
• Alert investigation requires evidence, rationale, and retained documentation.

Terms to remember

CTR

Cash Transaction Report for threshold-based cash reporting.

STR/SAR

Suspicious Transaction or Activity Report submitted when behaviour may indicate financial crime.

Transaction Monitoring

Ongoing review of customer activity to identify unusual or suspicious patterns.

Core idea

Case work trains judgement. A good investigation compares customer profile, activity pattern, counterparties, source and use of funds, geography, documentation, and customer explanation before deciding whether to close, monitor, escalate, or report.

Key takeaways

• A case study should identify facts, risk indicators, gaps, and next actions.
• The same red flag can have different meaning depending on customer profile.
• A clear closing rationale is as important as an escalation rationale.

Core idea

Customer Due Diligence is not only document collection. It is the process of identifying, verifying, understanding, risk-rating, and monitoring the customer relationship. CDD failures often create downstream monitoring failures because alerts are judged against weak or incomplete customer profiles.

Key takeaways

• CDD covers identity, verification, purpose, ownership, risk rating, and monitoring.
• KYC and beneficial ownership information are core to risk understanding.
• EDD applies to higher-risk customers, PEPs, high-risk geographies, and other elevated-risk relationships.
• Transaction profile and screening data support future monitoring.

Terms to remember

CDD

Customer Due Diligence: identify, verify, understand, risk-rate, and monitor the relationship.

Beneficial Owner

The natural person with ultimate ownership or control.

EDD

Enhanced Due Diligence for higher-risk customers or circumstances.

Core idea

Banking instruments and channels affect how quickly value moves, who controls the instruction, what evidence is available, and how easy it is to identify the real party behind activity.

Key takeaways

• Instrument risk and channel risk should be considered with customer risk.
• Digital and remote channels can increase speed and reduce face-to-face context.
• Case review should compare instrument use with customer profile.

Core idea

Bangladesh's AML/CFT regime is shaped by domestic law, BFIU guidance, reporting-organization obligations, sanctions obligations, and international standards such as FATF-style expectations and regional assessment processes.

Key takeaways

• International standards influence domestic AML/CFT regulation.
• Reporting organizations have legal, operational, and governance responsibilities.
• Failure can lead to fines, punishment, regulatory findings, and reputational impact.
• Risk management should be documented and proportionate to the institution's exposure.

Core idea

BFIU receives and analyses financial intelligence, issues guidance, supervises reporting organizations, coordinates domestically and internationally, and responds to evolving financial crime risks.

Key takeaways

• BFIU connects reporting entities, intelligence, supervision, and enforcement outcomes.
• Emerging risks include online gaming, betting, digital hundi, forex, crypto, fintech products, and misuse of payment channels.
• Regulatory response requires detection, escalation, documentation, and reporting.

Terms to remember

BFIU

Bangladesh Financial Intelligence Unit.

Digital Hundi

Informal value transfer using digital banking or payment channels.

Core idea

Trade-Based Money Laundering disguises criminal proceeds through trade transactions by manipulating invoices, quantity, quality, shipment, documents, parties, routes, or payment instructions.

Key takeaways

• TBML techniques include over-invoicing, under-invoicing, multiple invoicing, false description, short shipment, over shipment, and phantom shipment.
• Trade review requires comparing customer profile, trade partner, goods, price, route, documents, and payment flow.
• A Trade Transaction Profile helps establish expected trade activity.

Terms to remember

TBML

Trade-Based Money Laundering.

TTP

Trade Transaction Profile.

Core idea

Credit-Based Money Laundering can use loans, repayments, collateral, refinancing, third-party payments, shell borrowers, and inflated business activity to justify or integrate suspicious funds.

Key takeaways

• Credit products can be used for placement, layering, and integration.
• Repayment source and borrower legitimacy are central to review.
• Connected parties, vague purpose, and unusual early repayment are important risk indicators.

Core idea

Sanctions and ABC controls protect the institution from prohibited dealings, improper influence, facilitation payments, conflicts of interest, hidden ownership, and circumvention attempts.

Key takeaways

• Bribery includes anything of value used to induce or reward improper performance.
• Facilitation payments are bribery even when they appear customary.
• Sanctions risk includes direct, indirect, ownership, routing, and circumvention concerns.

Terms to remember

ABC

Anti-Bribery and Corruption.

Sanctions Circumvention

Conduct intended to hide, route around, or avoid sanctions restrictions.

Core idea

Transaction monitoring investigation compares profile, pattern, counterparty, source and use of funds, channel, geography, and explanation. Virtual assets and digital platforms increase speed, anonymity, cross-border access, and layering risk.

Key takeaways

• Monitoring should connect red flags to customer context.
• Risk mitigation requires investigation, escalation, restriction, or reporting depending on facts.
• Virtual assets can create exposure through counterparties, payment references, digital hundi, online betting, and platform layering.

Core idea

The final session consolidates learning across the course: banking system risks, account typologies, AML/CFT, monitoring, CDD/KYC, BFIU and regulatory standards, TBML/CBML, sanctions, ABC, virtual assets, and investigation judgement.

Key takeaways

• Use the course schedule as a revision checklist.
• Connect each topic to practical FCC decision-making.
• Final review should focus on concepts, controls, red flags, and case judgement.