Currently, GRMCT is actively providing consultancies in Europe and the Middle East to prevent the financial crime and especially the one committed by the opportunistic of COVID-19. Hence, GRMCT is absolutely referring to FATF in the following: The increase in COVID-19-related crimes, such as fraud, cybercrime, misdirection or exploitation of government funds or international financial assistance, is creating new sources of proceeds for illicit actors. Measures to contain COVID-19 are impacting on the criminal economy and changing criminal behavior so that profit-driven criminals may move to other forms of illegal conduct. The COVID-19 pandemic is also impacting government and private sectors’ abilities to implement anti-money laundering and counter terrorist financing (AML/CFT) obligations from supervision, regulation and policy reform to suspicious transaction reporting and international cooperation. These threats and vulnerabilities represent emerging money laundering (ML) and terrorist financing (TF) risks. Such risks could result in: Criminals finding ways to bypass customer due diligence measures; Increased misuse of online financial services and virtual assets to move and conceal illicit funds; Exploiting economic stimulus measures and insolvency schemes as a means for natural and legal persons to conceal and launder illicit proceeds; Increased use of the unregulated financial sector, creating additional opportunities for criminals to launder illicit funds; Misuse and misappropriation of domestic and international financial aid and emergency funding; Criminals and terrorists exploiting COVID-19 and the associated economic downturn to move into new cash-intensive and high-liquidity lines of business in developing countries. AML/CFT policy responses can help support the swift and effective implementation of measures to respond to COVID-19, while managing new risks and vulnerabilities. These include: Domestic coordination to assess the impact of COVID-19 on AML/CFT risks and systems; o Strengthened communication with the private sector; Encouraging the full use of a risk-based approach to customer due diligence; Supporting electronic and digital payment options.  

Lately, GRMCT is supporting professionals, such as lawyers, accountants, company formation agents, auditors and other financial intermediaries, who have the ability to either block or facilitate the entry of illegitimate money into the financial system to perform their screening responsibilities successfully.  That is GRMCT provides sanctions screening services. The responsibilities of such gatekeepers include requiring them to identify clients, to conduct due diligence on their clients, to maintain records about their clients and to report “suspicious” client activities. Some of these rules also prohibit gatekeepers from informing or “tipping off” clients who are the subject of the suspicious transaction reports. Violations may subject gatekeepers to prosecution, fines and even imprisonment. In the European Union and several other countries, mandatory anti money laundering duties already apply to “gatekeepers.” The FATF 40 Recommendations also cover independent legal, including lawyers and legal professionals, and other “gatekeepers.” In its typology report of 2000-2001, FATF says that the following functions provided by lawyers, notaries, accountants and other professionals are the most useful to a potential money launderer: Creating corporate vehicles or other complex legal arrangements, such as trusts. Such arrangements may serve to confuse the links between the proceeds of a crime and the perpetrator. Buying or selling property. Property transfers serve as either the cover for transfers of illegal funds (layering stage) or the final investment of proceeds after they Performing financial transactions. Sometimes these professionals may carry out various financial operations on behalf of the client (for example, issuing and cashing checks, making deposits, withdrawing funds from accounts, engaging in retail foreign exchange operations, buying and selling stock, and sending and receiving international funds transfers). Providing financial and tax advice. Criminals with large amounts of money to invest may pose as individuals hoping to minimize tax liabilities or seeking to place assets out of reach in order to avoid future liabilities. Providing introductions to financial institutions.  

GRMCT sells and supports an advanced Technology Business Intelligence Application for Compliance and Anti Financial Crime to grant for its clientele (Financial and Designated Non-Financial Institutions) the robust implementation of FATF recommendations such as but not limited to: To establish a computerized central archive for information collected about money laundering and terrorist financing operations. To not close any suspicious account before referring to the FIU. To maintain a special registry with the names of the persons that open or activate accounts by proxy. To impose, for employees’ recruitment, the highest standards of honesty, integrity and efficiency. To deal only with the intermediaries that meet the criteria required from banks and financial institutions towards their customers, and to promptly obtain from them the information required under the due diligence principle. To maintain and update a special register with the names of the Beneficial Owners that were identified relative to each (Customer/natural person) and only when the Customer is not the Beneficial Owner himself, and relative to each (Customer/legal person). To identify and assess ML/TF risks that might arise due to the development of new products and new business practices, including new mechanisms for service delivery, and due to the use of new or developing technologies for both new and pre-existing products.  To assess ML/FT risks prior to the launch or use of the new products, business practices, or technologies, and take appropriate measures to manage and mitigate those risks.