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Course overview

This course analyses in details how Administrative Service providers (ASPs) and in general Licensed Entities can designed and implement an effective Risk Based Approach (RBA) regime. ASPs are at a high risk of being used for money laundering or terrorist financing because of the services they offer. In this respect ASPs need to set out clear requirements for collecting “know your client” information and for conducting verification of identity, to a depth suitable for the assessment of risk. For clients that are classified as high risk, Enhanced Due Diligence (EDD) measures are required.

Course Description

This course explains and analyses RBA and describes the steps that ASPs should design and implement for the implementation of the RBA. It also explains and analyses the four main categories of risk namely country/geographic risk, client risk, transaction/service risk and delivery channel risk and explains how ASPs can identify the ML/TF risk factors in accordance with their risk appetite.

In addition, explains and analyses specific high risk situations that ASPs should apply enhanced due diligence (EDD), like PEPs, clients from high risk third countries, transactions that are complex, unusually large, follow an unusual pattern, or lack apparent economic or lawful purpose, etc, and describes the measures that ASPs should apply for each specific high risk client.

It explains the purpose of contacting risk assessment and how the results of a risk assessment can be used. It furthermore explains why ASPs must have a holistic view of the ML/TF risk factors and that the assessment of the ML/TF risk should be proportionate to the nature and size of the firm.

In addition, this course analyses the internal mechanisms of ASPs to ensure compliance and that senior management should monitor effectiveness of firms’ internal controls.

Topics covered

The course is split into the following sections:

Section 1: Risk-Based Approach (RBA)

  • What are the main businesses of the ASPs?
  • Why ASPs are vulnerable for ML/TF?
  • What is the Risk-Based Approach (RBA)?
  • Application of the Risk Based approach
  • Tone at the top

Section 2: Risk identification

  • Identifying and Assessing risk
  • How to identify risk
  • Indicators to be considered for each identified risk factor
    • Client Risk
    • Service/transaction risk
    • Country/Geographical risk
    • Delivery Channel Risk

Section 3: Specific High-Risk Situations

  • Enhanced Due Diligence (EDD)
  • Other factors to consider
  • Politically Exposed Persons (PEPs)
  • Clients from high-risk third countries
  • Transactions that are complex, unusually large, follow an unusual pattern, or lack apparent economic or lawful purpose
  • Cyprus Investment Program (CIP)
  • Standard/Simplified/Enhanced CDD measures
  • CDD Measures – Verification and certification

Section 4: Risk assessment

  • Variables that may impact on a RBA and risk
  • What is the purpose of a risk assessment?
  • Assess the level of risk
  • Weighting risk factors
  • Risk Scoring
  • Documentation of risk assessments
  • Risk mitigation
  • An indicative guideline for the evaluation of automated ‘off-the-shelf’ systems for the prevention of money laundering and terrorist financing

Section 5: Internal controls for an effective RBA

  • Internal controls and compliance
  • Internal controls and governance
  • Internal mechanisms to ensure compliance
  • Vetting and recruitment
  • Education, training and awareness

Course Duration:

This course may take up to 5 hours to be completed. However, actual study time differs as each learner uses their own training pace.

The course is addressed to:

This course is addressed to all individuals who practice Anti-Money Laundering such as:

  • Compliance/AML Managers in Banks, Investment Firms, Investment Funds, ASPs, Trust Service Corporate Providers, Accountants, Auditors and Lawyers.
  • Employees of Banks, Investment Firms, Investment Funds, ASPs, Trust Service Corporate Providers, Accountants, Auditors and Law Firms involved in KYC/CDD
  • Internal Auditors
  • Consultants
  • Senior managers
  • Directors

It is also suitable to professionals pursuing CPD in Anti-Money Laundering for the renewal of CySEC’s AML Certificate or other relevant certificates in other jurisdictions.

Training Method

The course is offered fully online using a self-paced approach. The learning units consist of power point presentations. Learners may start, stop and resume their training at any time.

At the end of the course, participants take a Quiz to complete the course and earn a Certificate of Completion once the Quiz has been passed successfully.

Accreditation and CPD Recognition

The course can be accredited by regulators and other bodies for 5 CPD Units that require CPD training in Anti-Money Laundering. The course may be also approved for up to 5 CPD Units by institutions that approve general financial and AML training, such as the CySEC, ICPAC, CBA, CISI, ICA and ACAMS.

Eligibility criteria and CPD Units are verified directly by your association or other bodies in which you hold membership.

Registration and Access

To register to this course, click on the Take this course button to pay online and receive your access instantly. If you are purchasing this course on behalf of others, please be advised that you will need to create or use their personal profile before finalizing your payment.

Access to the course is valid for 60 days.

If you wish to receive an invoice instead of paying online, please Contact us by email. Talk to us for our special Corporate Group rates.


George Papanicolaou has more than 20-years experience in the Financial industry. He worked for several years in managerial positions as area Manager, Head of Brokerage, Compliance Officer, Anti Money Laundering Officer, General Manager and Executive Director in Cypriot Investment Firms as well as Managing Director of GP GLOBAL LTD offering consulting services and training courses to Investment Firms, focuses in Internal Audit, compliance & AML issues. He offered numerous courses/seminars both in Cyprus and abroad in Investment Firms Law as well as in Compliance & Anti Money Laundering. George Papanicolaou is also a Chairman of a Nomination Committee in a company listed in the Oslo Stock Exchange.

George Papanicolaou holds a BSc in Electronic Engineering from the University of Texas at Austin (USA), an MBA with specialization in Finance from Leicester University (UK) and a Postgraduate Certificate in the Mechanics of Risk Management from Middlesex University (UK).

He also holds an ICA International Diploma in Anti Money Laundering from the International Compliance Association and the University of Manchester, as well as an Advance and Money Laundering certificate from the Cyprus Securities and Exchange Commission for the provision of investment services/activities.

He is a Fellow of the International Compliance Association (FICA), Mentor of ICA new students, member of the Cyprus Institute of Internal Auditors and Network chair for Cyprus of the International Compliance association.

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