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Annual Employee  Compliance Training 2020-2021

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Culture of Compliance Importance of Training Money Laundering & Terrorist Financing FASU & MSB PNG AML Laws AML / CTF Act 2015  Customer Identification Program (CIP) Customer Due Diligence (CDD) Suspicious Matter  Reporting Consumer Fraud Prevention Risks of Non-Compliance Enforcement Action Trends Summary  Conclusion

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Digicel  Financial Services compliance  area has embraced the following guidance for Fostering a Culture of AML Compliance Globally:

Leadership must actively support and understand their organization’s compliance efforts.  Management & The Board should  set the tone of Compliance from the Top

Revenue interests should not compromise  AML  risk-management  efforts.   Compliance  should have the authority and autonomy to work independently

Compliance  staff  should be given all relevant information.  Compliance should  make aware and communicate  all AML  risks  affecting the company

Adequate budget, people and technological resources must be devoted to Compliance.   The Compliance Department should be managed by  knowledgeable persons

Independent   testing  is crucial.  Periodic, unbiased,  and independent  reviews   performed on the existing  Compliance    program

Management  &  the  Board  should   know  and instill an effective AML/CTF Program  and  communicate  the  reasons for   why it’s important for the company to comply

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Digicel  Financial Services' culture of  Compliance Digicel  Financial Services has incorporated these guidelines into their own compliance program.  This training program is a prime example of  Digicel’s  commitment to fostering a culture of compliance by providing its employees with the information and knowledge required to identify the process of money laundering, the laws that make it a crime, why it is important and how to detect and report suspicious activity.  In addition, employees gain a better understanding of their role and responsibilities regarding compliance within the organization.   Digicel’s  Compliance Department is dedicated to developing and maintaining a compliance program consistent that will help mitigate the risks of being  a  Money Service Business (“MSB”) by constantly updating employees and the Board on issues as they arise to continuously foster the culture of compliance that is required.

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This training is of utmost importance because  Digicel  (PNG) Financial Services Limited (DFSL)  is registered with  the financial  Analysis Supervision Unit (FASU) as a Money Services Business (“MSB”), and as such, is required to comply with all laws and regulations related to anti-money laundering (“AML”) and combating the financing of terrorism (“CFT ”). One of the main requirements of having an effective AML /CTF program is that of compliance training.  As an employee of DFSL (PNG) you must understand your role and responsibility as it pertains to these AML/CFT laws and regulations . These responsibilities include taking the compliance training and passing the exam, adhering to  the compliance  policies and procedures provided, and reporting any suspicious activity to compliance, among  others .

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What  guidelines  Digicel Financial Services Compliance area is fostering to instill a Culture of Compliance globally?  Who must actively support and understand their Organization’s compliance efforts and set the tone of Compliance Management? What must not comprise AML risk-management efforts Who is primarily responsible communicating all AML risks affecting the Company?  What is crucial for an unbiased  compliance program within the Organization?

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Module 2.  Introduction to MONEY LAUNDERING &                    TERRORIST FINANCING (ML/TF)

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Money Laundering is the criminal practice of filtering ill-gotten gains or “dirty” money through a series of transactions, so that the funds are “washed” to look “clean” like proceeds from legal activities.   Worldwide Money Laundering amounts to approximately 2-5% of global GDP or anywhere between $800 million - $2 trillion USD a year.  In most cases, it is associated with unlawful activities such as:   			Drug Trafficking		Human Trafficking  			Arms Trafficking		Human Smuggling  			Tax Evasion		Terrorism   Due to advances in technology such as the development of crypto currencies and widely used mobile communications, the speed and ease of moving money and value globally has made it easier to launder money and it has become harder to detect it. Wire transfers and prepaid cards, especially electronic cards are services often used by criminals to launder money.

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There are three stages of money laundering:   Placement   -  placing the proceeds of crime in the financial system. (i.e. conducting a money transfer or loading a                            mobile  wallet or a prepaid card, etc.)   Layering   - converting the proceeds of crime into another form and creating complex layers of financial transactions                          to  disguise the audit trail and the source and ownership of funds (i.e. breaking up transactions into  multiple                         small  loads or transfers to the same beneficiary or various beneficiaries.) Integration  - integrating the “laundered” funds back into the legitimate economic and financial system where it is                             assimilated  with all other assets in the system. (i.e. using the funds received to purchase goods and services.)

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W h a t   i s   t er r o r i s t   f in a ncin g ?  T err o r i s t   f in a ncin g   i s   ch a r a c t er i z e d   b y  the   following :   Funds   aimed   at   sponsoring   terrorist   activities   with   the   purpose   of   causing   fear   in   a   so c i ety .   The   origin  of   the money   may   be   legal   or   illegal.   May   or   may   not   be   re la te d   to   money  laundering.   The   motivation   behind   terrorist   financing   is   ideological   and   not   the   pursuit   of   economic   benefits .   The   difference   is   that   money   launderers   send   illegal   funds   through   legal   channels   in   order   to   conceal   their   criminal   origins,   whereas   those   who   finance   terrorism   may   send   funds   that   may   be   legal   and/or   illegal   in   origin   to   disguise   their   ultimate   criminal   use.

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Module 3.	 Introduction to PNG AML Laws &                        Regulations

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The   Financial Analysis Supervision Unit (FASU)   is   the   financial   intelligence   unit   or   (“FIU”)   in  PNG.   It   provides   government   support   in   the   detection,   investigation,   and   prosecution  of   domestic   and  international   money   laundering,   terrorist   financing,   and   other financial crimes. Following are institutions that must register with FASU and comply with AML Laws & regulations:  Commercial Banks, Financial Institutions, Merchant banks, Savings & loan societies, Superannuation funds, Insurance companies,  Money remitters, Money changers, Foreign exchange dealers.   Digicel  (PNG) Financial Services Limited is registered with FASU as a mobile financial business.  Its services include international (inward) money remittance and domestic mobile payments.

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The Proceeds of Crime Act 2005 was the first AML legislation enacted in 2005 and now refers to the series of AML laws and regulations that have been enacted over the past fifteen years. It was last amended in 2015 as  the Proceeds of Crime (Amended) Act 2015 to include the fight against terrorist financing. Here are the highlights of the different legislation passed over the years starting with:  Proceeds of Crime Act 2005, the POCA established requirements for ‘cash dealers’ to:       -  establish customer identification and verification       -  obtain customer information and maintain records       -  report the movement of money and monetary instruments of PGK10,000 and over by filing a Cash           Transaction Report (CTR)       -  report the electronic movement of funds of PGK10,000 and over by filing an Electronic Funds Transfer           Report (EFT)       -  report any suspicious transactions by completing a Suspicious Transaction Report (STR)

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FASU:- Who is FASU and what is their function?                                                                                                                    Who are the institutions that must register with FASU and comply with AML laws & regulations? Is Digicel Financial Services required to register with FASU as a Mobile Financial Business? Proceeds of Crime Act 2005:- Name 2 requirements under the  Proceeds of Crime Act 2005 ? Give 2 examples of the process or procedure you perform in your area of duty that meet the 2 requirements? What is required when establishing identification and verification of a customer?

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Module   5:  Customer Identification Program

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Pursuant to federal regulations,  Digicel  has developed a comprehensive CIP policy with corresponding identification verification to further enhance its customer due diligence program. When a customer wishes to establish an account with  Digicel , the following guidelines will be followed for all new customer accounts :

New accounts will only be activated once the customer’s true identity has been satisfactorily verified New   accounts  will  not  be  established  for  customers  who  refuse  to provide identification Digicel   will provide customers with adequate notice to comply with its identification verification procedures   If fraud or identity theft is suspected,  Digicel   will follow the established escalating and reporting procedures

New accounts will only be activated once the customer’s true identity has been satisfactorily verified New  accounts  will  not  be  established  for  customers  who  refuse  to provide identification Digicel  will provide customers with adequate notice to comply with its identification verification procedures   If fraud or identity theft is suspected,  Digicel  will follow the established escalating and reporting procedures

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The following information is required from each customer prior to registering an account with DFSL (PNG) As part of its Customer Identification Program (CIP),and Know Your Customer (KYC), you must first identify and assess the level of risk you are faced with when dealing with a customer’s request to open an account. At a minimum the Financial Institution must obtain but not limited to: Full name,  Unique identification number and photographic identification ( such as an identity card number, birth certificate number or a passport number, or where the customer is not a natural person, the incorporation number or business registration number) Existing residential address, registered or business address (as may deemed appropriate) and contact telephone numbers Date of birth, place of birth, incorporation or registration (as may deemed appropriate) Nationality or place of incorporation or registration (as may deemed appropriate) Where the AI is a company, the directors of the company and the beneficial owners of the company must be identified .

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A Financial Institution must NOT open an account under the following circumstances:          1.  Under an anonymous or  fictitious name          2.  Full Identification and verification process/procedures cannot be completed          3.  Where there is suspicion of money laundering and terrorists financing activities linked  to  the customer          4.  Customer is on Sanctioned Listing          5.  Customer has a criminal record relating to fraud and or  corruption

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Customer Identification Program (CIP):-  What information is DFS required to obtain from an individual, before establishing a business relationship? What information is DFS required to obtain from a business, or company entity before establishing a business relationship? Under what circumstances should DFS NOT establish business relationship with a customer?

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Module 6.  Customer Due Diligence - CDD                       	    Obligations

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AML / CTF Act 2015 – Obligation on Financial Institutions  and Designated Non Financial Businesses and Professions

Anti-Money Laundering & Counter Terrorist Financing Act 2015 was made law in 2015, which made money laundering activities, including structuring of transactions to avoid reporting; and financing of terrorism a criminal offence under the  Criminal Code (Money Laundering & Terrorist Financing) (Amendment) Act 2015.   The AML/CTF Act 2015 established requirements for Financial Institutions and Designated Non-Financial Businesses and Professions.   These requirements are highlighted in the headings as follows : CUSTOMER DUE DILIGENCE       -  conduct  due diligence when  an electronic fund transfer amount is equal to or greater than PGK 2,500.           - conduct  standard customer due diligence to obtain information on the purpose and nature of  the          business  relationship,       -  conduct  due diligence on electronic funds transfer customers whether domestic or international to obtain           names, addresses, place   birth , date of birth for a natural  person; for  a body corporate, its name,            a  unique reference or number,  physical addresses,          proof  of incorporation, identity  of  its directors and beneficial owners

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ONGOING DUE DILIGENCE         -    maintain current and up to date information and records of  customers and its beneficial ownership         -    ensure  customers transactions are known and consistent with its products and services its business is               associated  with         -   ensure Politically Exposed Persons (PEP) transaction activities are monitored on an ongoing basis         -    ensure  correspondent banking relationships are established subject to Senior Management approval and             are maintained in adherence to the AML/CTF  controls  ENHANCED CUSTOMER DUE DILIGENCE         -   conduct enhanced due diligence on Politically Exposed Persons (PEP) or a customer from a high risk country,            or involved in a high risk business or beneficiary of an insurance policy or if the person is not physically present           for identification or to verify the source or wealth of the customer         -  must verify identity of a person or incorporated entity when carrying out an occasional transaction            equal to PGK20,000 or greater

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AML / CTF 2015 –  Obligations …cont’d

WHERE CUSTOMER DUE DILIGENCE CANNOT BE COMPLETED, A FINANCIAL  INSTITUTION        -    must  not establish any new business relationship       -   must  cease any existing business relationship       -   must  not carry out any occasional transaction       -   an  ordering institution must not effect an electronic funds transfer equivalent to K2,500 or greater if it           does  not            have  the required customer identification information to transmit       -   an  intermediary institution must assess whether to carry out, suspend or reject an electronic funds            transfer  equivalent  to K2,500  or greater  if it does not receive all the identification required  to           accompany  the  transaction        -    a  beneficiary institution must assess whether to carry out, suspend or reject an electronic funds  transfer          of  K2,500  if it does not  receive all the identification information  required to accompany the  transaction           from  an ordering institution or  an intermediary  institution        -   must  not establish any business relationship with a shell bank where it does not have a physical presence       -   must  not establish or maintain business relationship with a correspondent bank that permits its accounts  to            be  used  by a shell bank

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Customer Due Diligence (CDD):- What is customer due diligence? What are the tasks involved in performing a customer due diligence? Ongoing Due Diligence (ODC):- What is ongoing due diligence? What are the tasks involved in performing an ongoing due diligence? Enhanced Customer Due Diligence (ECDD) :- What is enhanced customer due diligence What are the tasks involved in performing enhanced customer due diligence? Where Customer Due Diligence Cannot be completed (CDD):- What are some of the actions you must take when CDD cannot be completed ?

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Financial Institution and Designated Non-Financial Businesses & Professions – Reporting Obligations

Reporting Obligation        -  compile  and report cash transaction equivalent to or greater then PGK20,000 within ten (10) days of when the             transaction transpired.        -  compile  and report domestic electronic funds transfer equivalent or greater than K20,000 within ten (10) days of             when  the transaction  transpired.        -  compile  and report international money transfer equivalent or greater than K20,000 within ten (10) days of            when the  transaction  transpired.        -  report  any assets held of a designated person or entity         - compile  a suspicious transaction report if the nature surrounding one or more transaction does not make economic  sense            or  is unusual in  nature. Remember,  any acts or omission done in good faith in discharge under obligations of this Act is protected from  civil, criminal  liability, action, claim or  demand.

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What are Digicel Financial Services reporting obligations What is the threshold reporting limit for both domestic and international transactions? Are you protected from civil, criminal liability, action or claim or demand when you perform any  acts or omission done in good faith in discharge under obligations of  this Act?

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AML Regulations on Financial Institutions

The United National Financial Sanctions Act 2015 (PNG) sets out prohibitions on:          -  dealing with assets belonging to  or owned by, held or controlled by (directly or indirectly) by a               designated person or entity (‘asset freezes’) end,           -  making assets or financial services available directly or indirectly to, or for the benefit of a  designated              person or  entity. A Financial Institution’s key roles are to implement:          -  Effective procedures in tracing/following assets          -  Effective KYC Practices          -  Effective CDD procedures including beneficial ownership information          -  Robust Asset freezing procedures in place          -  Processes for guiding against false positives in identification of designated persons/entities          -  Effective communication channels with and reporting to FASU and the Sanctions  Secretariat

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Module 8.  Suspicious Matter Reporting (SMR)

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Suspicious Matter Report (SMR)      A  Financial Institution (FI) must report suspicious matters as soon as practicable  or within maximum 5 working days . This          applies where a FI has reasonable grounds to suspect that information known to it may:        A. Be  relevant to the detection, investigation or prosecution of a person for money laundering, terrorist financing or an               offence  under section 15 or 16 of the United Nations Financial Sanctions Act  2015         B. Be  relevant to the detection, investigation or prosecution of a person for a foreign indictable offence; or concerning               criminal property.         C. It  is an offence to intentionally or recklessly fail to comply with these reporting requirements. It is also an offence to              provide  false or misleading  information or reports.

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Suspicious Activity: Structuring & Money Mules

Money mules also conduct similar tasks when structuring transactions. Money mules are either willingly recruited or unknowingly recruited through job vacancy and “work-from-home” ads or job and temp-for-hire websites The money mule is convinced to work for a fake company that may go as far as soliciting personal identifiable information through official-looking contracts or employment forms Once the money mule is recruited and activated, they receive illicit funds into their bank account The money mule is then instructed to remove the funds from their account and send them to another party, less a commission, using wire or money transfers. They can also take the funds and load them onto a prepaid card.

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Suspicious Activity Red Flags – Money Transmission

When interacting with the customer, reviewing activity or monitoring transactions, be on the lookout for suspicious activity that could include the following “Red Flags” for  money transmission : Structuring of transactions by sending money to multiple beneficiaries on the same day or consecutive days Unusual transactions that are not in line with the customer’s profile   Multiple customers sending transfers to the same beneficiary on the same day or consecutive days Customers making multiple high dollar transfers to the same beneficiary on the same day or consecutive days A customer admits to criminal  conduct

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Suspicious Activity Red Flags – Remittance

When interacting with the customer, reviewing activity or monitoring transactions, be on the lookout for suspicious activity that could include the following “Red Flags” for remittances:   A customer who is unwilling to provide information required by KYC A customer who presents unusual or suspicious identification documents that cannot be readily verified A customer uses different tax identification numbers with variations of his or her name High dollar deposits followed by numerous small withdrawals A Cardholder who makes multiple value loads on the same day at different load locations using multiple cards Transactions occurring in more than one state or country on the same day or with relative frequency Repetitive transactions occurring at the same time for the same amount each day or each week As an employee of  Digicel  Financial Services  it is your responsibility to notify Compliance of any suspicious activity detected.  You can contact the Compliance Department via email at:  Compliance@DigicelGroup.com .

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Willful Blindness is avoiding or ignoring information, which could have led to the discovery of unlawful  activity       Ignoring  “red flags” that indicate a customer could be involved in suspicious activity could lead to civil        and  criminal penalties for  Digicel .  A  person committing an act of willful blindness can be held responsible for whatever knowledge an         investigation  would have revealed. According to the law, a person can be convicted of money  laundering        if  it can be proven that they were “willfully blind” in their actions. Therefore, it is very important to         recognize  “Red Flags” and report them to Compliance immediately .

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Suspicious Matter Report :- When do you complete a Suspicious Matter Report (SMR)? Give 2 examples of a suspicious transaction? Money Transmission :- What is structuring of transactions? Give 2 examples of structuring transactions?  Money Mules :- What is a money mule? Give an example of a money mule? Willful Blindness:- What is willful blindness? Give an example of willful blindness

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Why it’s important to understand Sanctions? Because you are an employee of  Digicel  it’s important to understand the obligations in relation to domestic and international sanctions, and how they may potentially impact the business before entering into arrangements with offshore customers and/or their agents . If you are to allow the following transactions you are at risk of a sanctions violation: •  The  customer make a payment directly to someone who is subject to a sanctions or embargoes program. •  The  customer make a payment to someone in a sanctioned country, even if their account is located in a       non-sanctioned  country. •  The  movement of funds and/or goods in your transaction involves a party who is subject to  sanctions     (for example  airlines, banks, shipping vessels and ports). •  The  ultimate recipient of your goods/service may be subject to sanctions despite you only dealing with      a non-  sanctioned  intermediary.

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As a licensed  MSB,  Digicel   cannot conduct transactions on behalf of persons or entities that are on the sanctions lists. Therefore, if  Digicel   were to process a transaction for a name, country, entity, organization, or vessel that is found on the sanction list, there would be penalties imposed for non- compliance.   Digicel   has processes in place to monitor transactions against the names on the sanction list.   Failure to comply with sanctions Regulations can expose  Digicel   to  severe  civil and criminal penalties including : Cease & Desist Order preventing  Digicel  from conducting ANY transactions Monetary  losses resulting from penalties & fines Substantial legal fees

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Digicel’s   Sanction Compliance Program To ensure that  Digicel   does not process any transaction for any entity on the sanctions lists, it has established policies, procedures, and controls to screen customers prior to activating an account or processing a transaction. As part of its sanction program,  Digicel   does the following: Identify and review potential matches Timely obtains sanctions list updates File the appropriate reports when necessary Maintain license information as applicable Digicel   uses Optima to screen all new account applicants in real time.  In addition,  Digicel   screens all active account holders against the multiple sanctions lists on a bi-monthly basis.  Any potential matches are reviewed and cleared as necessary. For those customers where a match cannot be cleared, a compliance alert is created and sent to the Compliance Officer for further review.  If the alert cannot be cleared, the account is suspended or blocked until verification can be obtained.

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What to do if a true reportable match is  detected-:   Depending  on  the  Sanctions  program,  the  transaction  either  must  be rejected or blocked. For those transactions that must be rejected,  Digicel   will not allow the customer to establish an account or allow a money transfer to go through for payment. For those transactions that must be blocked,    Digicel   freezes the funds and does the following: Hold the funds in a segregated interest-bearing account Report the match within ten (10) days of the occurrence Report all blocked property to on an annual basis by September 30th for balances as of June 30th 9(what does that mean?) Retain all related reporting and supporting documentation for five (5) years

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What is a Sanctions List What is the AML System DFS use to screen accounts and transactions? What do you do if a true reportable match is detected? Why is it important to understand Sanctions

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The  Federal Trade Commission (FTC) reported in the 2019 Consumer Sentinel Data Report that during                      the  previous calendar year, American consumers lost $1.48 billion to fraud and the average                      transaction  was $375. Likely victims: any unsuspecting consumer but especially senior citizens 60+ years of age   Some of the most common scams: Relative in need or grandparent scam Government imposter scam (pretending to be an IRS or law enforcement agent) Romance Scams Employment or investment opportunity scams (“too good to be true”) Lottery or sweepstakes scams (“too good to be true”)   Millions of Americans fall victim to scams and are convinced by fraudsters to give-up their hard-earned money through deceit, trickery and deception.

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Fraudsters contact their potential victims by phone (i.e. telemarketing scams) or via email or social media with a seemingly believable story that is “too good to be true” or requires them to URGENTLY send money via wire transfer or by loading a prepaid card . 	The  FTC requires financial institutions to take reasonable steps to prevent fraudsters from using them  to receive                   their victims ’ money.   	If  you suspect that a customer may potentially be a victim of fraud: 	Ask  them questions: “Did anyone  instruct you  to send this money via phone, email?” “Did you check with your son/daughter to  make sure your grandchild is actually in financial need?” Inform them that they may be a victim of fraud or a scam and should reconsider sending the money or loading the card. If your role in the company is to monitor transactions and you suspect a customer may be a victim of a scam,  inform       your  Compliance Officer .

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What type of consumer fraud is Digicel Financial Services likely to face?  How do you prevent these types of consumer fraud Are you familiar with the Dodd-Frank Act?

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PNG’s first National Risk Assessment (NRA) on AML/CTF was conducted between 1 June 2016 and 30 September 2017. In its findings, the NRA concluded the main predicate offences in PNG are: Corruption and Bribery Fraud against government programs and activities Illegal logging and fishing                                                                                                              Taxation and revenue fraud Other Environmental Offences Illicit drug importation and  distribution

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AML/CTF Predicate Offences in PNG…Cont’d

The sectors that are most vulnerable are:				 Domestic banks; Company/trust formation; Currency Transfer and Exchange Businesses Real Estate Agents, Lawyers and accountants engaged in commercial activities on behalf of clients; and                                               Motor vehicle dealers The  structural vulnerabilities in PNG were found to include: Porous borders A cash based economy and a significant informal sector Capacity & skills shortages within government agencies non-bank financial reporting entities in the DNFBP sector Weakness in the regulatory and legislative framework (such as lack of supervision of the NPO sector); and  Lack of inter-agency co-ordination and co-operation

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What is a predicate Offence? What are the predicate offences in PNG? Which sectors are the most vulnerable to these offences? Is Digicel Financial Services vulnerable to these offences?

Annual Employee Compliance Training 2020-2021

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