- Senior management of banks are to implement board-approved money laundering/terror financing policies.
- Bank staff are to prepare periodic reports on money laundering and terrorism finance for their senior management and boards of the bank and also communicate these to the CBK.
- Financial institutions will be required to appoint a money laundering reporting officer who will be the point of contact for CBK.
- Banks should assess and rank TF and ML instances and actions in terms of high, moderate, and low risk.
- They should identify countries and regions that are high risk for business; high-risk includes countries subject to sanctions from the UN and other credible organizations, countries that don’t have appropriate banking safeguards and countries known to sponsor terrorism.
- Banks are to assess their customers for money laundering and terror financing risks; suspicious customer activities include frequent and unexplained movements of money to other accounts, or other institutions, and to far locations. They should also look at politically exposed persons who bank with them including prominent public figures, senior politicians, judicial officers, corporate CEO’s who dealing with them, or their families, may bring a reputational risk to the bank.
- Banks are to assess their service delivery channels for money laundering risks. They are to pay attention to cash-intensive businesses, including supermarkets, convenience stores, restaurants, retail stores, liquor stores, wholesale distributors, car dealers.
There have been two recent attacks which have looked like they were motivated by terrorists, but which now appear to have been linked to investors with issues or seeking gains
There was the deadly attack in Manila, Philippines on a casino and shopping complex that’s now attributed to a heavily indebted Filipino (a, former finance department employee who owed more than $80,000, and had sold off some property) who was hooked on gambling (his family had even asked casinos in the capital to ban him) …authorities released security footage showing Carlos casually exiting a taxi just after midnight and walking calmly into a vast entertainment and gambling complex like any other visitor. Shortly afterward, he dons a black ski mask, slips on an ammunition vest and pulls an M4 carbine assault rifle out of his backpack…at least 37 patrons and employees died, mostly from smoke inhalation as they tried to hide
But more shocking was the bus attack back in April on the team bus of a German soccer team.
- In what seems like a plot from a James Bond movie, police arrested a man on suspicion he attacked the bus of German soccer team Borussia Dortmund GmbH last week as part of a scheme to profit from a slump in the club’s share price.
- The man stayed in the same hotel as the soccer team, with a room overlooking the site of the attack. He bought put options online via the IP address of the hotel, the prosecutor’s office said. The options grant their owner the right to sell shares at a fixed price in the future. The man had taken out a loan to finance the transaction, according to the statement.
- On the day of the April 11 attack in the team’s home city, he bought 15,000 options on Borussia Dortmund shares, betting they would drop sharply after the attack. (On the day of the attack, 15,000 equity-covered put options were traded at 18 cents a piece at 11:16 a.m. in Frankfurt, about 8 hours before the bombs went off. The options, issued by DZ Bank AG and due to expire on June 16, give the right to sell Borussia Dortmund shares at 5.20 euros. The shares closed at 5.61 euros that afternoon, shortly before the attack took place, and fell as low as 5.50 euros the next day. The stock hasn’t traded below 5.20 euros since February. DZ Bank declined to comment. The suspect bought three types of derivatives, with the suspicious trades leading authorities to the man)
- The man later placed three bombs in a hedge on the road that the team bus was due to take to the stadium, prosecutors said. The explosives contained metal pins, which after the explosion were found as far as 250 meters (275 yards) away. One pin was found in a head-rest of one the bus seats, the authorities said.
- “A massive share drop would have had to be expected, had a player been gravely injured or even killed as the result of the attack,” the prosecutor’s office said. Police are still calculating what the maximum profit could have been had the plot gone as planned, she said.
- Borussia Dortmund said in a statement that it hopes all details of the plot will be cleared up in order to help the team, one of the few to be publicly traded, cope with the trauma caused by the incident.
Here in Kenya, we don’t have many mass attacks linked to such, but there are numerous stories of people who have taken their lives after gambling losses.
At one time the IRA used to bomb the British mainland with impunity while enjoying some local sympathy and receiving funds from Irish-American causes. But now that other terrorists have taken over, bombing it is no longer ‘acceptable’ and the IRA has now decided to end violent actions against Britain. It’s like when a new bully shows up in a school, who’s stronger, badder and crazier than the reigning school bully, the incumbent bully realizes that he doesn’t scare and no one fears/cares about him anymore – and so loses and gets a haircut, cleans up his act and tries new things such as becoming a better student.