AML_Reports & Papers

[Paper] 「A Study on high-risk customer management for enhanced Anti-Money Laundering effectiveness」 「자금세탁방지 효율성 제고를 위한 고위험고객 관리방안 연구」 2024.8 이태연

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「A Study on high-risk customer management for enhanced Anti-Money Laundering effectiveness」 

Table of Contents

Chapter 1 Introduction 1

Section 1 Purpose of the Study 1

Section 2 Scope and Methodology of the Study 3

Chapter 2 Customer Risk Management in the Anti-Money Laundering System 5

Section 1 Legal and Regulatory Requirements for Customer Due Diligence 5

  1. Significance and Necessity 5
  2. Types of Customer Due Diligence 5
  3. Risk Assessment 7
  4. Subjects of Customer Due Diligence 11
  5. Timing of Implementation 12

Section 2 High-Risk Customer Management 13

  1. Enhanced Due Diligence 13
  2. Subjects and Additional Measures 14
  3. Other Risk Management by Financial Institutions 19

Chapter 3 Issues in Managing High-Risk Customers 25

Section 1 Institutional Limitations 25

  1. Limited Scope of High-Risk Customers 25

A. Limitations in the Legal Scope 25

B. Insufficient Requirements for Continuous Customer Due Diligence 28

  1. Limitations in Suspicious Transaction Reporting Management 30

A. Prohibition of Disclosure 30

B. Insufficient Follow-Up Measures after Suspicious Transaction Reporting 31

C. Inadequate Management of Customers Providing Information to Law Enforcement Agencies 33

  1. Limitations of Terminating Business Relationships 34

A. Legal Restrictions on Terminating Business Relationships 34

B. Issues in Risk Management Based on RBA 35

C. Insufficient Procedures for Terminating Business Relationships 37

Section 2 Operational Limitations 39

  1. Limitations in Compliance with Internal Control Requirements 39

A. Role and Responsibility of Management 39

B. Limitations in Management Due to Information Sharing Restrictions 40

  1. Lack of Information for Customer Due Diligence 42

A. Methods for Collecting Beneficial Ownership Information 42

B. Insufficient Understanding of Ownership Structure 45

C. Exploitation of Differing Procedures among Financial Institutions 46

  1. Inadequacies in Managing Watchlisted Individuals 47

A. Watchlist Search Requirements 47

B. Limitations of Search Data 49

C. Restrictions on Watchlist Management Systems 50

Chapter 4 Measures to Enhance High-Risk Customer Management 52

Section 1 Institutional Improvements 52

  1. Legal and Regulatory Improvements 52

A. Sharing Information on High-Risk Customers 52

B. Legal and Regulatory Improvements for Beneficial Ownership Verification 56

C. Strengthening Requirements for Terminating Business Relationships 63

  1. Improvements in Management Requirements 67

A. Inclusion of Qualitative Risk Management Requirements 67

B. Standardization across the Industry 72

Section 2 Operational Enhancements 72

  1. Establishment of Management Guidelines by Regulatory Authorities 72
  2. Development of Industry-Specific Guidelines 76

A. Guidelines Reflecting the Characteristics of New Industries 76

B. Establishment of Industry-Specific Standards through Self-Regulatory Organizations (SROs) 77

Chapter 5 Conclusion 80

References 83

ABSTRACT 86


「자금세탁방지 효율성 제고를 위한 고위험고객 관리방안 연구」

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