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Anti-Money Laundering - Prodigy Newsbyte

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					                                  Prodigy Newsbyte
Special points of              Issue 6                                                                           Feb to Apr 2004
interest:                      Fundamental Controls for Effective Anti-Money
• Fundamental Controls for     Laundering and Legal Compliance
  Effective Anti-Money
                               Fundamental controls are important for effective         the legal status of businesses opening accounts,
  Laundering and Legal
                               anti-money laundering systems and legal compli-          bankers should determine the source of funds and
  Compliance
                               ance. These controls include effective Bank Se-          the beneficial owners of all accounts. The exis-
• Detecting Money Laun-        crecy Act (BSA) compliance and customer due              tence of most businesses can be verified through
  dering in Banking with       diligence programs, compliance with Office of For-       an information-reporting agency, banking refer-
  ACL — The 3 Stages of        eign Assets Control (OFAC) guidelines, suspicious        ences, or by visiting the customer’s business.
  Money Laundering             activity monitoring and reporting systems, and risk-
                                                                                        Screen Against OFAC and Other Govern-
                               based anti-money laundering programs.
                                                                                        ment Lists
• Elements of a sound AML
                               Establish Effective BSA Compliance Pro-                  OFAC administers and enforces economic and
  program for life insurance
                               grams                                                    trade sanctions against targeted foreign countries,
  companies
                               Banks must develop, administer, and maintain a           terrorism-sponsoring organizations, and interna-
• ACL Training Promotion       program that ensures and monitors compliance             tional narcotics traffickers based on U.S. foreign
                               with the BSA, including record keeping and report-       policy and national security goals. OFAC acts
• RTI & AML Solution           ing requirements. A bank’s compliance program            under presidential wartime and national emer-
  Suites                       must be written, approved by the board of direc-         gency powers and the authority granted by spe-
                               tors, and noted as such in the board meeting min-        cific legislation to impose controls on transactions
                               utes. The program must also contain:                     and to freeze foreign assets under U.S. jurisdic-
                               • A system of internal controls to ensure ongoing        tion. Many of the sanctions are based on United
                                  BSA compliance.                                       Nations and other international mandates, are
                               • Daily coordination and monitoring of compli-           allied countries. OFAC has promulgated regula-
                                  ance by a designated person.                          tions to help administer its sanctions program.
Inside this issue:             • Training for appropriate personnel                     All U.S. persons and entities, including banks,
                               • Independent testing of compliance (by internal         federal branches and agencies, international bank-
                                  auditors or an outside party)                         ing facilities, and overseas branches, offices and
ACL Useful Tips         2                                                               subsidiaries of U.S. banks must comply with the
                               Establish Effective Customer Due Diligence               laws and OFAC-issued regulations. In general,
Detecting Money     2          Systems and Monitoring Programs                          these regulations require blocking of accounts and
Laundering in Bank-            Comprehensive customer due diligence programs            other assets of specified countries, entities, and
ing with ACL —                 are banks’ most effective weapons against being          persons; and prohibit unlicensed trade and finan-
The 3 Stages of                used unwittingly to launder money or to support          cial transactions with specified countries, entities,
Money Laundering               terrorist financing. Knowing customers, including        and persons
                               depositors and other users of bank services, re-         Banks should establish and maintain effective
Elements of a sound 3          quiring appropriate identification, and being alert to   OFAC compliance programs. This program
AML program for                unusual or suspicious transactions can help deter        should include written policies and procedures for
life insurance com-            and detect money laundering and terrorist financing      checking transactions for possible OFAC viola-
panies                         schemes. Effective due diligence systems are also        tions, designating a person responsible for day-to-
                               fundamental to help ensure compliance with suspi-        day compliance, establishing and maintaining
ACL Training Pro-       4      cious activity reporting regulations. These regula-      strong lines of communication between depart-
motion in Malaysia             tions require banks to report transactions that          ments of the bank, employee training, and an an-
                               have no apparent lawful purpose or are not the           nual in-depth audit of OFAC compliance. The
RTI & AML Solution 4           sort in which the particular customer would be           compliance program should also include proce-
Suites                         expected to engage.                                      dures for maintaining current lists of blocked
                               The first and most essential step in effective cus-      countries, entities, and persons and for dissemi-
ACL Asia Pacific        5      tomer due diligence is verifying the identity of the     nating such information throughout the bank’s
User Conference                customer. Present guidelines for the opening of          domestic operations and its offshore branches
2004                           personal accounts include: obtain satisfactory cus-      and offices. All new accounts, including deposit,
                               tomer identification; consider the proximity of          loan, trust, or other relationships must be com-
Practical Course to 6          customer’s residence or place of business; call-         pared with the OFAC lists when accounts are
Proactive Risk Man-            verify the customer’s residence or place of employ-      opened. Established accounts should be com-
                               ment; consider source of funds used to open ac-          pared regularly with the current and updated
agement Workshop
                               count; and check prior banking references for lar-       OFAC lists. Wire transfers, letter of credit, and
                               ger accounts. Additional steps may include third-        non-customer transactions, such as funds transfer,
On A Lighter Side       6      party reference, verification services, and use of
                               Internet search techniques. In addition to verifying                                  ...Continued in Page 2
                                     Issue 6
                                     ...Continued from Page 1                                 on the risks posed by the products and services
                                                                                              offered, customers served, and geographies.
                                     should be compared with the OFAC lists before            Below are examples of high-risk products and
                                     being conducted.                                         services, customers, and geographic locations of
                                     Establish an Effective Suspicious Activity Moni-         which banks should be aware when developing a
                                     toring and Reporting Process                             risk-based anti-money laundering program.
                                     An effective BSA compliance program includes             High-Risk Products and Services
                                     controls and measures to identify and report suspi-      • Wire Transfer/International Correspondent
                                     cious transactions promptly. Financial institutions         Banking
ACL Useful Tips                      must employ appropriate customer due diligence
                                     to effectively evaluate transactions and conclude
                                                                                              • Private Banking Relationships
                                                                                              • Electronic Banking
   ACL Tips of                       whether to file a suspicious activity report (SAR).
                                     Bank must file SARs within prescribed timeframes.        High-Risk Customers
                                                                                              • Non-bank Financial Institutions (NBFI), includ-
Dothe Month —
                                     SARs must be filed following the discovering of
  you experience                     transactions aggregating $5,000 or more that in-           ing Money Service Businesses
  Detecting in field
inconsistenciesCorporate             volve potential money laundering or violations of        • Non-governmental Organisations
format definitions for your
   Credit Card Abuse!                the BSA if the bank knows, suspects, or has reason       • Offshore corporations, bearer share corpora-
company records? One                 to suspect that the transaction:                           tions, and banks located in tax and/or secrecy
common issue faced by                • Involves funds from illegal activities or is con-        havens and jurisdictions designated as non-
large corporations is these             ducted to hide illicit funds or assets in a plan to     cooperative in the fight against ML
inconsistencies caused by               violate or evade any law or regulation or to          • Cash-intensive businesses
data migration across legacy
                                        avoid transaction reporting requirements under        High-Risk Geographic Locations
systems. An illustration is
                                        federal law.                                          Identifying high-risk geographic locations is es-
shown below:
                                     • Is designed to evade any of the BSA regulations.       sential to a bank’s anti-money laundering pro-
                                     • Has no business or apparent lawful purpose or is       gram. Information regarding possible high-risk
PO Number               Amount
Loc01-MachineTools-02   1000.23         not the sort in which the customer would nor-         geographic locations is available from:
Loc02Joints(12)         215.45          mally be expected to engage, and the bank knows       • Jurisdictions identified by intergovernmental
Loc03 LCD-11            900.21          of no reasonable explanation for the transaction        organisations as non-cooperative in the fight
                                        after examining available facts                         against money laundering
Instead of creating multiple         The bank’s board of directors must be notified of        • Countries/jurisdictions identified by the U.S.
computed fields to derive            SAR filings, and such filings and information con-         Department of State’s annual International
each segment of details              tained therein must remain confidential, unless            Narcotics Control Strategy Report (INCSR)
using different separators for       properly requested by law enforcement. Financial           as “primary concern”.
each case, it will be more           institutions are protected from liability to consum-     • Geographics identified by OFAC.
effective to adopt the               ers for disclosures of possible violations of law        • Jurisdictions designated by Secretary of the
following approach:                  under safe harbour provisions.                             Treasury as being of primary money launder-
                                     Additionally, the safe harbour covers all reports          ing concern as authorised by USA Patriot Act.
• Remove all instances of            (including supporting SAR documentation) of sus-         • Jurisdictions identified by bank management.
 separators using EXCLUDE            pected or known criminal violations and suspicious
                                     activities to law enforcement and the financial insti-   Identifying customers and transactions from
 function:                                                                                    high-risk geographic locations is crucial in con-
                                     tution’s supervisory authority.
 EXCLUDE(fieldname, “- )(”)                                                                   trolling money laundering and terrorist financing
                                     Develop Risk-Based Anti-Money Laundering                 risk. By obtaining such information, bankers can
• Add separator at consistent        Programs                                                 develop or modify policies, procedures, and
 position in each record             Bank anti-money laundering programs should be            controls addressing the risks associated with
 INSERT(fieldname, “-“, 6)           structured to address the controls needed based          those locations.

• Proceed to derive the individual
 segment of the records using        Detecting Money Laundering in Banking with ACL —
 the SPLIT function:
 SPLIT(fieldname, “-“, 1)
                                     The 3 Stages of Money Laundering
                                     Stage 1 — Placement
                                     The initial or “placement” stage is when illegal earnings enter the financial system. This is also the
                                     point where the launderer is most vulnerable to detection. Since large amounts of cash are involved,
                                     it is extremely difficult to place the money in a bank account legitimately and without rousing suspi-
                                     cion from bank employees and investigators. Using the software’s joining and relating capabilities,
                                     auditors can detect suspicious deposit and withdrawal patterns such as small structured cash deposits
                                     followed by suspiciously infrequent and large withdrawals.
                                     To get around regulatory controls, money launders often structure their cash deposits at an amount
                                     under $10,000. Since banks have thousands upon thousands of deposits a day, investigators need the
                                     ability to quickly analyse large amounts of data and identify records that fall within the range of suspi-
                                     cion. Investigators can take advantage of the unlimited file size capacity of ACL to quickly analyse
                                     transactional files and filter for deposits that fall within a specified dollar range. The filtered results
                                     can then be grouped so that the auditor can spot individuals or companies showing frequent deposits
                                     within the range of suspicion. These suspected accounts are then combined with the wire transfer
                                     files, enabling the investigator to quickly isolate the pattern of structured deposits followed by a
                                     money wire transaction.
                                                                                                                        ...Continued in Page 4
Issue 6                                                                               Page 3

Elements of a sound Anti-Money Laundering (AML)
program for life insurance companies
The USA Patriot Act, enacted after the attacks     priorities. Developing a risk assessment in-
of September 11, 2001, was designed to pro-        volves analyzing the company’s products, dis-
vide law enforcement with additional tools to      tribution channels and customer base.
combat terrorism. The law created important        Question to consider include: How are the
obligations for financial services institutions    products purchased? Do you receive cash or
that increase communication between law en-        equivalent? How is money moved? How well
forcement and companies and require scrutiny       do you know the sales force? Are there lim-
of customers. Among the requirements for life      its money that may be put into or taken out
insurers is creation of an anti-money laundering   of the product? How easy is it for the con-
(AML) program, which includes identifying legal    tract holder to get money out of the prod-
requirements and assigning resources; complet-     uct?
ing an AML risk assessment; developing a writ-     The risk assessment allows the business areas
ten AML program; identifying an AML compli-        to identify particular procedures or policies
ance officer; communicating to and training        that are susceptible to money laundering.
employees; and independent testing of AML
program compliance.                                Developing a Written ACL Program
                                                   After you have sufficient resources and have
Identify Legal Requirements                        identified the risks, you must develop and
The new AML obligations, mainly found in Title     implement your AML program. Depending on
III of the USA Patriot Act, extend the Bank        the size and complexity of your organization,
Secrecy Act’s many anti-money laundering obli-     formal project management support may be
gations to other financial institutions, including advisable. You must develop a written policy
life insurers, and impose new compliance and       and operating procedures. Internal audits
reporting requirements.                            should be engaged in the process, since you
AML requirements for life insurers have been       should expect an annual evaluation of your
proposed, with final regulations expected later    AML program, and that will generally be per-
this summer. As Treasury issues further AML        formed by the internal audit function.
regulations, including final rules on suspicious
                                ACL enhanced Identifying FRAUD COURSE
activity reporting, programs must be SPECIALISEDan AML Compliance Officer
to reflect those changes.                          Your designated AML compliance officer
                                                   should be an executive who is senior in the
Allocate Internal Resources                        organisation, has the skills to establish com-
Once the requirements for a program are iden- pliance systems and has the judgment and
tified, insurers must allocate the resources to initiative to oversee a complex risk-
implement it. Executive management must management program.
make implementation a priority and communi-
cate that priority to the organization. Since Communicating and Training
AML obligations are relatively new to the insur- Communication and training of employees
ance industry, most companies will need to buy and producers are necessary to ensure suc-
or develop internal AML expertise. In addition cess of your company’s program. The act
to the legal and compliance areas, resources requires ongoing employee training. Provid-
must also be identified from each line of busi- ing ongoing communications from executive
ness, information technology, project manage- management and line-of-business manage-
ment and internal audit.                           ment will maintain employee awareness levels
                                                   necessary to a successful program. The train-
Develop a Risk Assessment                          ing should enable employees to understand
Regulations proposed by The Treasury Depart- what money laundering is, the risk assessment
ment require life insurers to develop an AML of each line of business, and the AML pro-
program that is reasonably designed to present gram requirements.
money laundering and terrorist financing. The
program should take into account the risk pro- Independent Testing
file of each line of business. Treasury should be At least annually, your AML program should
                                                                                                    PRODIGY DATA SOLUTION

commended for taking this risk-based ap- be tested to ensure that the program is both                 79B PAGODA STREET
proach, since not all life insurance products adequately designed and operating effectively.           SINGAPORE 059238
have the same potential for use in money laun- Finally, the financial institution’s board of di-        TEL: (65) 6221 2810
dering or terrorist financing, and implementing rectors or senior management should ad-                 FAX: (65) 6221 2813
                                                                                                    INFO@PRODIGY.COM.SG
an AML program is expensive. A risk assess- dress findings or recommendations from the
ment is important in setting your program’s testing.
                                                                                                                         Page 4
PRODIGY DATA SOLUTION
                                  ...Continued from Page 2
  79B PAGODA STREET
   SINGAPORE 059238
                                  Stage 2 — Layering
    TEL: (65) 6221 2810
    FAX: (65) 6221 2813           The second stage is “layering”, which is the process of avoiding detection and legitimizing cash. Of-
INFO@PRODIGY.COM.SG               ten, funds are transferred dozens of times through multiple accounts, companies, and countries, mak-
                                  ing the paper trail virtually impossible to follow. Wire transfers play a prominent role in the clean-
                                  sing of dirty money. Although financial institutions must report bank deposits that exceed a certain
                                  limit, there are no such restrictions on wire transfers. The onus is on the banks to determine if cer-
                                  tain activities appear to be suspect and report them accordingly.
                                  Investigators can use data analysis software to identify frequent wire transfers from one bank account
                                  to another that have not been pre-designated as a “repetitive code” by the customer and the bank
                                  representative. If the summarized count or amount is greater than a number predetermined by the
                                  investigator, the transaction stream is earmarked for further investigation.
   PROMOTION
                                  Stage 3 — Integration
                                  Integration, the third and final stage in money laundering, takes place when the money is returned to
                                  its originator as “legitimate” income. This is where the launder is least vulnerable to detection.
                                  Money can be returned to its launderer in a variety of ways such as “loan-back” (the launderer essen-
                                  tially borrows money from himself by setting up various foreign accounts), wire transfers, and with-
 ACL Training                     drawals. Investigators should pay special attention to accounts where funds are frequently converted
                                  to other currencies, corporate accounts where deposits and withdrawals are primarily in the form of
  in Malaysia                     cash, and funds that are deposited as cash or wired into accounts and then withdrawn from overseas
                                  ATM networks.

 Sign up any open
enrolment training                      Prodigy Data Solution Pte Ltd is pleased to bring you our newly
  course below in                                     launched RTI ACL Solution Suites.
April 2004 to Enjoy                 With intense competition, tight markets and an increasingly uncertain economy, improv-
the Special Promo-                                         ing financial performance is a high priority for every business.
   tional Rates!                                           Mining valuable information out of a large and complex database
                                                           is frequently a long and tedious task taking weeks or months of
                                                           hard work by skilled data analysts. This is not something an
Sign up 1-2 participants:                                  organisation can afford to do often! Understanding the impor-
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 ACL 201     US$385                 automated Solution Suites to ensure you see fast results and gain increased confidence in
 ACL 301     US$280                 the corporate data underlying your financial reporting.
 ACL 302     US$525
 ACL 303     US$700                 These suites, brand as the “Ready-To-Implement (RTI) ACL Solution Suites”, consists of
                                    standard applications that are ready to implement to your existing analysis and reporting.
                                    The RTI Solution Suites focus on three key areas – (1) Trends Monitoring, (2) Control
Sign up 3 or more participants:
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Course Name Promo Rates             tion suites is to ensure essential controls compliance and audit tests through continuous
 ACL 105     US$500                 monitoring and at the same time, free your valuable staff resources to focus on critical
 ACL 201     US$360                 analysis and investigation, and to resolving potential weaknesses or deficiencies in inter-
 ACL 301     US$255                 nal controls and core business processes. These suites can be repeated any time on a
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 ACL 303     US$675                 Solution Suites are categoried into 4 functional areas, namely Accounts Payable, Ac-
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For more information on                     ANTI MONEY LAUNDERING (AML) SOLUTION SUITES
the training promotion,
please email us at                  Prodigy has developed a series of solution suites that can help identify potential money
info@prodigy.com.sg                 laundering problems. These suites can be put into use quickly and easily resulting in im-
                                    mediate time and financial savings. The AML Solution Suites harness the robust function-
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                                    unique situations. Drill down capability is standard to assist investigators with their analy-
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                                                                                      Page 5


                               PRODIGY NEWS & EVENTS                                                  visit us at
                                                                                                  www.prodigy.com.sg
                            ACL ASIA PACIFIC USER CONFERENCE 2004
                        Achieving Best Practice Standards for Corporate Governance
                                 The Westin Kuala Lumpur, 6 – 7 July 2004

Prodigy Data Solution cordially invites you to the inaugural event – ACL Asia Pacific User
Conference 2004. Due to numerous requests from our key users in the region, this inaugural
event has been rescheduled to be held from 6-7 July 2004 at The Westin Kuala Lumpur,
Malaysia.
                                                                                                   ACL ASIA USER
Themed “ Achieving Best Practice Standards for Corporate Governance ”, this coming                 CONFERENCE
conference will be focusing on critical issues relating to corporate governance. We have con-
gregated the pioneer users of ACL from Malaysia , Philippines , India , Indonesia and Singa-          is BACK!
pore at the conference to share their valuable real life experiences and knowledge on the im-
plementation of ACL in their organisation. This is indeed a rare opportunity for you to meet up   Prodigy is pleased to
face to face with many other ACL users and learn from the more experienced users. A series           bring back the
of networking sessions over coffee breaks, lunch and dinner have also been arranged for you
to mingle and get to know each other in the same field across industries and countries.
                                                                                                       ACL Asia
                                                                                                  User Conference —
2-day Conference Programme                                                                            to be held in
                                                                                                   The Westin Kuala
Session 1                                    Session 6
                                                                                                     Lumpur from
The Internal Auditor's Role Now & Beyond - A From CAATs to SAT (Software Audit Tool)
Sharing from San Miguel Group Audit          using ACL and Forensic Audit using ACL                  6-7 July 2004.
Vicci Tomas, Chief Executive of Group Audit  Nishith Seth, Partner
San Miguel Corporation, Philippines          S. K. Seth & Co., Chartered Accountants, India
                                                                                                  For more information, please
Session 2                                         Session 7                                       contact info@prodigy.com.sg
Working with ACL for Greater Effectiveness        Successful ACL Implementation for Managers         or tel: (65) 6221-2810
and Efficiency                                    Michael Kano, Manager, Global Training Ops
Adiat Sarman, Head of Internal Audit              ACL Services Ltd, Canada
Total E&P Indonesie, Indonesia
                                                  Session 8
Session 3                                         Using CAATTs in SAP R/3 Environment
Enhancing Risk-Based Auditing in a Banking        Abhay A. Phalke, Head (Shared Services)
Environment                                       TATA Motors Ltd, India
Elizabeth Abbott, Program Director, AP Con-
sumer, Audit & Risk Review                        Session 9
Citigroup – Singapore                             Achieving Enterprise-Wide Business Assur-
                                                  ance through ACL Server Editions
Session 4                                         Alan Soon, Senior Consultant
Bangko Sentral ng Philipinas’ (BSP) Improved      Prodigy Data Solution Pte Ltd, Singapore
IT Operations through ACL
Bella S. Santos, Internal Audit Office            Session 10
Bangko Sentral ng Pilipinas, Philippines          Trends in Data Analysis
                                                  Robert Fuller, VP, Development
Session 5                                         ACL Services Ltd, Canada
System Quality Assurance for Banks
Surendran Nair Sankaran, Head of Ops - Malaysia


We are pleased to extend the early bird fee of
US$355 per participant till 15 May 2004 . Seats are
limited and are based on first come first served ba-
sis. We urge you to register early to confirm your
attendance at the conference. For more information
on the pricing and group registration, please contact
us at (65) 6221-2810 or email us at
info@prodigy.com.sg.
                                                                                                                     Page 6
PRODIGY DATA SOLUTION
                                A 2-Day Practical Course to Proactive Risk Management Workshop
   79B PAGODA STREET
    SINGAPORE 059238
                                         20-21 May 2004, Hotel Rendezvous, Singapore
     TEL: (65) 6221 2810   Industry Focus — Ministries, Government Agencies, Statutory Boards, Government Link Companies
     FAX: (65) 6221 2813   (GLCs) and related
 INFO@PRODIGY.COM.SG
                           Benefits of Attending
                           • Learn how to define Risk Management
                           • Gain an understanding of current thinking and issues in Integrated Risk Management
                           • Understanding the scope of Integrated Risk Management
                           • Become familiar with the Risk Management process
                           • Develop the capability to assess your organisation's Risk Management profile
                           • Learn effective approaches to developing a ‘Risk Aware' organisational culture
                           • Acquire an understanding of the need to implement Risk Management software to manage risks effectively,
                             including reporting to senior management and external stakeholder

                           Who Should Attend — Department Directors, Finance Managers, Operational Managers, Risk and
                           Compliance Managers, Project Managers, Auditors, Anyone concerned with internal controls
                           Course Outline

                           DAY ONE                                              DAY TWO
                           Integrated Risk Management                           Case Study
                           · What is Integrated Risk Management and why         An exercise in applying risk management based on
                                does it apply to you                            the development of an infrastructure project which
                           · Different Risk Categories and Frameworks           affected a number of government departments.
                           · A Risk Management standard (AS/NZS 4360),
                                becoming an internationally recognised std      Design of Organisational Risk Management
                           · Risk Appetite                                      Programme
Coming Up in the           · Stakeholder Involvement
                                                                                · Implementing a Risk Management Programme
Next Issue of              · Corporate Governance and Risk Management
                                                                                · Establishment of a positive Organisational
                           · Compliance Programmes and Risk
Prodigy Newsbyte                Management
                                                                                    ‘Risk Aware' culture
                                                                                · Risk Monitoring, Evaluation, Audit and
                                                                                    Reporting
♦ More Useful              The Risk Management Process (Broad Brush             · Measuring the effectiveness of Risk
                           Qualitative Approach)
  ACL Tips                                                                          Management Programmes
                           · Risk Context
♦ More Articles            · Format of Risk Molecules (Risk, Consequence        Additional Areas of Risk Management (Time
  on Financial                 and 2 types of Controls)                         Permitting)
                           · Determining Residual Risk Ratings
  Management               · Action Planning, including Traps and how to
                                                                                · Introduction to Risk Quantification
                                                                                · Emerging Risk Disciplines
♦ ACL User                     avoid them
  Feature                  · Ongoing monitoring and review, including the
                               importance of maintaining Risk Profiles
♦ And many                 · Dynamic Risk Management – what is it and
  other useful                 why is it important?
                           · Control Frameworks COSO and COCO
  industries
  information              (Including government case study examples –
                           misuse of and effective use of information)


                           For more information on the RM workshop, kindly email donald@prodigy.com.sg or info@prodigy.com.sg


                                            On A Lighter Side
Feel free to write us
any questions,
comments or
feedbacks on
Prodigy Newsbyte
via email at
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