A big warm welcome to iSON BPO.

We're delighted to have you on board, and we hope you're settling in nicely.

When you've finished taking this short course, you will:

Have fun!

About Money Laundering

What is money laundering and terrorism financing?

Money laundering

Money laundering means the ways in which criminals change money and other assets into “clean money” or assets that have no obvious links to their criminal origins. The three basic stages of money laundering are

  • Placement. The attempt to place funds in the financial system without attracting attention.
  • Layering. The stage in the money-laundering process where funds are moved around to break the trail of investigation. This movement often involves a complex series of transactions aimed at creating confusion and complicating the paper trail.
  • Integration. This is the ultimate goal of the money-laundering process. Once the funds are placed into the financial system, and are hidden in the layering stage, additional transactions are used to create a semblance of legality. This is the ultimate goal as these transactions are meant to provide a plausible explanation, and also act as a cover, for the source of the funds.

An example of money laundering scheme

Sources of money laundering

Terrorism financing

Terrorism financing involves dealing with money or property that may be used for financing terrorist activities. The funds and property may be from either legitimate

or criminal sources. They may be in small amounts.

The methods used by terrorists to move money are substantially the same as those used by other criminals, such as:

1. Traditional financial institutions: Often, individual accounts are opened and small withdrawals and deposits of less than any legal reporting requirements are made in order to avoid the reporting requirements.

2. Alternative remittance systems: Unregulated remittance systems such as Hawala and Hundi are extensively used to transfer funds without any documentation.

3. Currency transfers: Cash is smuggled across borders, particularly through land crossings and sea shipments.

4. Trade financing: With the growth of terrorist-owned commercial firms, trade finance is increasingly being used

What is your role and responsibilities with regards to AML regulations?

  • Ensuring that no action is undertaken on behalf of a customer without a clear understanding of the purpose and background of the transaction(s) or activity(ies).
  • Reporting promptly to the compliance officer (money laundering reporting officer) where they have knowledge or suspicion of money laundering or the financing of terrorism, or where there are reasonable grounds to know of or suspect money laundering or terrorist financing.
  • Not tipping off any customer or other third party that a suspicion report has been made or their account is under investigation either internally by the compliance officer or externally by the Financial Intelligence Unit.
  • Assisting fully with any investigation.
  • Completing assigned AML training and successfully passing the modules assigned.

How to ensure AML Compliance

Customer Due Diligence (CDD)

CDD (and Know Your Customer) involves the following steps:

  • The firm’s standard account opening forms must be used in all cases. All forms held must be originals, completed in full, and signed. Facsimiles or photocopies are not acceptable.
  • Identification evidence must be obtained from all applicants even where a member of the staff or the management, another respected customer, or another group entity makes the introduction.
  • As no single form of identification can give sufficient assurance that a customer is genuine, the identification process will be cumulative. A person’s address is an essential part of identity and therefore separate verification of address is a requirement in addition to the verification of the customer’s name and/or identity.
  • This customer verification includes a PEP.
  • PEP is an individual who is, or has been, entrusted with a prominent public function in the country or a foreign country, or an individual who is, or has been, entrusted with a prominent function in an international organization, including family members and close associates
  • With respect to joint personal account holders, the identity of each applicant must be verified.
  • Where funds to be deposited are being supplied by, or on behalf of, a third party, the identity of the third party must also be established and verified

Know Your Customer (KYC) Process - Airtel Money Case

Customer Registration

In line with the Government directive instructing all telecommunication operators to register the details of their subscribers; we have an easy way for you to check if your line is fully registered.

Dial *100#, select option 2 "Manage my account' then select option 6 "Registration status".

You should get an SMS notification in a short while with your registration status.

Should the SMS mentioned above show that your line is not registered, go to your nearest Airtel shop, Airtel Money agent or dealer shop with your original form of identification.

Below are the required documents to be provided.

Submit only one document as applicable to you.

Verification Documents: Kenyan Citizen

  • Original identity card;
  • Original and valid passport;
  • Original service card for a member of the Kenya Defense Forces;
  • Original birth certificate;

For a Kenyan citizen not in possession of an original identification documents:

  • Police abstract and a certified copy of an identification document

For East African Residents:

  • An original national identity card;
  • An original passport;
  • An original East African passport;
  • Any other original and valid registration documents acceptable as national identification documents in the country of domicile

For a Foreign National

  • Original and valid passport;
  • Original alien card.

For a corporate person or a statutory body

  • Certificate of incorporation and an original national identity card or passport of at least one director;
  • Certificate of registration and original national identity card or passport of the proprietor or at least one partner; or the relevant legislation or Gazette notice establishing the statutory body


  • A minor who wishes to register a SIM-card shall be accompanied by his or her guardian possessing relevant identification particulars as set out above.
  • The telecommunications operator or agent shall record the date of birth of the minor.
  • A guardian accompanying the minor shall be registered as the subscriber of that particular SIM Card until the minor attains the age of majority.
  • Upon the minor attaining the age of majority a telecommunications operator shall advise a minor registered as a user to register his personal identification details within 90 days from the date of attaining the age of majority.
  • A person who does not register their identification particulars within 90 days from the date of attaining majority shall have their SIM-card suspended and deactivated.

*If you are a post paid subscriber or registered on Airtel Money, you are not required to register your line.

Monitoring transactions and activity(ies)

The most important safeguard against money laundering is the ability to detect suspicious activity(ies) and to take further action to prevent recurrence of such activity(ies). Therefore, managers/department managers should monitor all activity(ies) on an ongoing basis to ensure that

  • the level and nature of activity(ies) in the accounts is consistent with the customer’s known business or profession,
  • there are no unusual or suspicious transactions for which the firm does not have satisfactory explanations, and
  • all relevant information has been taken into account to assess whether there are any reasonable grounds to suspect money laundering.

Reviews of activity will be written and retained as required under the firm’s record-keeping policy.

Suspicious Activity Reporting (SARs)

What is suspicion?

As the types of transactions that may be used by a money launderer or a person involved in the financing of terrorist activities are almost unlimited,

it is difficult to define a suspicious transaction or activity. Suspicion is personal and subjective and falls far short of proof based on firm evidence. However,

a suspicion must at least have some foundation and not just be based on mere speculation.

A suspicious activity or transaction will often be

  • any transaction or instruction that is not logical from an economic or financial point of view, and
  • any transaction where the amount, duration, or other specific feature is inconsistent with the customer’s professional or business activities, or expected account activity(ies) based on knowledge of the customer and the transactions to be conducted.

Recognizing suspicions

The process of recognizing suspicions has three components:

  • Having sufficient knowledge about a customer’s normal expected activity.
  • With enough knowledge you are able to distinguish the abnormal or unusual from the normal or usual.

 As a result, you can then recognize what might be suspicious.

Click the link below to access regulatory guidance on SARs

SAR reporting Guide 2017

Record keeping

The minimum periods for which records must be maintained to comply with the requirements of the law. 

Records relating to a customer’s identity must be retained for at least 5 years from the date of closure of business with the client. The date on which the relationship with a customer ends is the date of

  • carrying out of a one-off transaction or the last in the series of transactions; or
  • ending of the business relationship, that is, the closing of an account

Risk-Based Approach to Managing AML/CFT Risk

What is a risk-based approach?

Generally, legislation requires firms to assess their money laundering and financing of terrorism (ML/FT) risks and determine how they will be managed. Consequently, the approach to AML/CFT has been documented as part of its anti-money-laundering policies and controls.

What are the steps in risk-based approach?A risk-based approach involves a number of discrete steps in ascertaining the most cost-effective and appropriate way to manage and mitigate the risks of ML/FT faced by a firm. 

These steps are to identify the ML/FT risks that are pertinent to the firm in relation to its

  • customers,
  • products,
  • delivery channels, and
  • geographical areas of operation.

The steps are as follows:

1. Identify the risks

2. Assess the risks 

3. Design and put in place controls to manage and reduce risks

4. Monitor and improve the effective operation of the risk-based controls

The benefits of a risk-based approach

A risk-based approach serves to balance the cost burden placed on the firm and its customers with a realistic assessment of the threat of the firm being used in connection with money laundering or terrorist financing. A risk-based approach focuses effort where it is needed and will have the maximum impact.

All new and high-risk customers and recognizes that the ML/FT threat to the firm varies across customers,jurisdictions, products, geographic regions, and delivery channels.

The risk-based approach recognizes that a customer’s profile can be determined at the start of the relationship, but that the profile of a customer’s financial behavior, which allows the firm to identify transactions or activity that may be unusual or suspicious, will build up only over time.

Case studies

Sample Anti-Money Laundering Policy and Procedures

President assents to POCAMLA (Amendment) Act 2017

Seven Family Bank officials to be charged with money laundering offences

Money laundering in mobile money

What next


Ready for the ride?

As much as we love autonomy, we also believe in setting some standards for our new employees to adhere to. This roadmap plots out a few milestones we'd like you to reach on your way to becoming a tried-and-true Tulyan.

How would you prioritise?

Prioritize the following goals in your first year at Tulys. [THIS LOOKS AS THOUGH IT'S NOT FINISHED]

You will be asked to complete a number of tasks on your way to meeting your goals for the year.

  • Meet your buddy
  • Understand the team products, projects and clients
  • Make a team presentation
  • Represent Tulys at a conference


Your team's key accounts

Your team specialises in strategizing around the Agile marketing solutions for clients in the food-manufacturing sector. Here are few of our major clients:

Just Co, Sunnyvale, California, USA

We have been helping Just co streamline their print and digital-marketing operations. We've used e-mail campaigns and analytics to support the initiative. 

PoC: Josh Smith and Rina Ray 

Baller, Mexico City, Mexico

Baller is an important client. We market their customer-relationship management software package, with great results. But we've also leveraged Angular JS to build the UI for the package and have set up several microsites to boot!

PoC: Geoff Good

What would you do?


Meet your buddy

Rebecca is your new buddy. She's here to help you get to know the ropes. If you're looking for help or advice, she can either help you directly or point you in the right direction.  With Rebecca as your buddy, you'll be able to get cracking in no time.

Rebecca's been with us for more than five years, and now heads up the digital-marketing group within your business unit. Her contact details are in your inbox!

Meet your Team

Lisa Hood, Sales Analyst

Bob Masie, Market Research Lead 

Nina Turner, Digital Marketing Champ

Jon Stead, Client Negotiation Lead 

Strategic Relationships

Building bridges and making connections are a quintessential part of Tulyan life. Here are a few questions that can help you strike up that first conversation with your teammates by the water cooler.

  • Which other teams and key stakeholders will we be working with? 
  • What other managers will we be working with from other teams?
  • What is the current strategy for my business area?
  • How does my area help implement the strategy?
  • In what ways will we be working with other teams when it comes to multi-team initiatives?
  • How have we been leveraging business opportunities? 
  • What are the top five things that the team needs to focus on? Where's the low-hanging fruit, and where are the toughest challenges? What about risks and issues? 
  • Any surprises I should be looking out for?

Do you know your team?



Here are a few golden do's and don'ts for meetings, lifted shamelessly from Harvard Business Review:

a) State views and ask genuine questions. This enables the team to shift from monologues and arguments to a conversation in which members can understand everyone’s point of view and be curious about the differences in their views.

b) Share all relevant information. This enables the team to develop a comprehensive, common set of information with which to solve problems and make decisions.Use specific examples and agree on what important words mean. This ensures that all team members are using the same words to mean the same thing.

c) Explain reasoning and intent. This enables members to understand how others reached their conclusions and see where team members’ reasoning differs.

d) Focus on interests, not positions. By moving from arguing about solutions to identifying needs that must be met in order to solve a problem, you reduce unproductive conflict and increase your ability to develop solutions that the full team is committed to.

e) Test assumptions and inferences. This ensures that the team is making decisions with valid information rather than with members’ private stories about what other team members believe and what their motives are. Jointly design next steps. This ensures that everyone is committed to moving forward together as a team. Discuss "undiscussable" issues. This ensures that the team addresses important issues that are hindering its results and that can be resolved only in a team meeting.




Approval Level

Signature(s) Required

Up to $2,000

Manager only

$2,000 to $50,000

Manager and Accountant (any level)

Up to $200,000

Sr Manager and Finance Mgr/Sr Mgr

Up to $500,000

Senior Director and Finance Manager

Up to $1 million

Vice-President and Finance Vice-President



Business travel 

Step 1

Immediate supervisor reviews all request for travel at least one week advance.

Step 2

Unit Manager checks the travel request against the project workload, and decides on approval.

Step 3

Chief Financial Officer checks travel costs against available travel budget for the current quarter.

Who should approve?

  • $2,000 to $50,000
    Manager and Accountant (any level)
  • Up to $500,000
    Senior Director and Finance Manager
  • Up to $2,000