Malaysia: Anti Money Laundering and Counter Financing of

Transcription

Malaysia: Anti Money Laundering and
Counter Financing of Terrorism Certifications
Study Handbook
First Edition October 2011
I005/1850
Contents
Welcome
III
Part 1: Introduction
1
Part 2: Study Approach and Requirements
7
Part 3: Assessment
17
Part 4: Administration
27
Part 5: Appendices
31
I
Welcome
Welcome to the course.
This Handbook provides the support information you will need throughout your studies for an IBBM/ICA
qualification. From guidance on planning study sessions, information on how to use website support and training
facilities, suggestions on how to best utilise the study materials and information about workshops, through to
how to approach the assignment and examination, this Handbook provides answers to some of the most common
study and administration queries whatever level programme you are studying for.
We hope you enjoy the course and find the information contained within this Handbook useful, but please do not
hesitate to contact us if you require clarification or guidance on any further issues.
William B Howarth
CEO
International Compliance Association
The Institute of Bankers Malaysia (IBBM) is delighted to support this programme. This Handbook is a useful tool for
all banking professionals in their efforts to acquire the global qualifications. With this in mind, it is our intention to
help you plan, manage and maximise your resources in your study and certification efforts.
We see the Handbook not just as a document but a systematic approach to ensuring your success in this
programme. The centre piece of our goals is to ensure you acquire the knowledge, achieve your learning goals and
share your experiences – all important in the context of your career development and client’s business.
All the best from us at IBBM.
Tay Kay Luan
Chief Executive
Institute of Bankers Malaysia (IBBM)
III
Part 1:
Introduction
Part 1:
Introduction
The International Compliance Association (ICA), working in association with the University of Manchester
Business School, Institute of Bankers Malaysia, Asian Institute of Finance (AIF) and the IBBM – Compliance Officers'
Networking Group (CONG) have developed a series of professional certifications in the field of anti money
laundering and counter financing of terrorism.
1. Parties to the Programmes
1.1 International Compliance Association (ICA)
The ICA is a professional organisation dedicated to the furtherance of best compliance, anti money
laundering (AML) and financial crime prevention (FCP) practice in the financial services sector. The ICA
transcends national boundaries by educating and supporting compliance professionals globally, through
the provision of internationally recognised qualifications, member information exchange and training.
1.2 Manchester Business School (MBS)
Manchester Business School is the largest campus-based business and management school in the UK. It
provides world-class business and management education to undergraduates, postgraduates, experienced
practitioners, and those with serious academic and research ambitions. It is an international and progressive
school, delivering cutting edge business thinking and teaching, informed by the contemporary commercial
environment. MBS is the quality assured educational partner of the ICA on all its programmes.
1.3 Institute of Bankers Malaysia (IBBM)
The Institute of Bankers Malaysia (IBBM) is devoted to providing world class education and learning services
as part of its mission to develop talent in the banking and financial services industry. It aims to be at the
forefront in the advancement of banking education and learning services; and are taking quantum leaps to
reshape the banking education landscape through innovations in the delivery of its value propositions.
Established in November 1977 as the professional educational body for the banking and financial services
industry in Malaysia, IBBM is governed by a Council comprising representatives from Bank Negara Malaysia,
the Association of Banks in Malaysia, Association of Finance Companies of Malaysia and the Malaysian
Investment Banking Association.
The role of IBBM is to facilitate the transfer of knowledge and skills through multi-pronged approaches
-training, certification, dissemination of information and advisory
1.4 Asian Institute of Finance (AIF)
The Asian Institute of Finance (AIF) is a registered company limited by guarantee, jointly established by Bank
Negara Malaysia and Securities Commission Malaysia in November 2008 and commenced operations in
January 2009. AIF's vision is to be an institution of global excellence that delivers professional and advancedlevel certification and qualifications, in support of the advancement of the financial services industry.
AIF also aims to be a thought leader in the areas of applied research and publication, risk management,
financial inclusion and professional development through AIF's Centres of Excellence. The establishment of
AIF signals the nation's commitment to a professional development partnership with financial institutions
in Malaysia and the region, and elevates Malaysia's role as a premier provider of comprehensive training
solutions for the financial services industry.
3
Qualifications Study Handbook
To achieve this goal, AIF works closely with four affiliate training institutes, namely Institut Bank-Bank
Malaysia (IBBM), Islamic Banking and Finance Institute Malaysia (IBFIM), The Malaysian Insurance Institute
(MI1) and Securities Industry Development Corporation (SIDC); as well as with the financial services industry
to build "world-class standards "the competencies and skills of human capital within the sector.
1.5 IBBM – Compliance Officers' Networking Group (CONG)
The Compliance Officers' Networking Group (CONG) under the auspices of IBBM was originally formed as an
advisory committee to IBBM to pursue learning programmes relevant to Compliance. Over the last few years,
CONG has grown in stature as a body representing compliance professionals in the banking industry where
the membership consists of Compliance Officers of all the institutions that are holding membership of IBBM.
CONG has been working with regulators and learning institutions in Malaysia to raise the professionalism
of the Compliance Function. The initiatives include the introduction of a standard framework or code for
Compliance, to introduce professional curriculum with international accreditation, enhance the relationship
between Compliance Officers, regulators and enforcement agencies and to introduce new and effective
capacity building initiatives to further improve Compliance standards in Malaysia.
2. ICA/IBBM Study Programmes
2.1 Range of Programmes
These are delivered via IBBM in both public and in-house format at three levels, as follows:
Malaysia
International
Experienced Practitioner Level
Certified Professional
in AML/CFT
Post Graduate
Diploma in
Anti Money Laundering
Advanced Level
Advanced Certification
in
AML/CFT
International
Diploma in Anti Money
Laundering
Intermediate Level
Certification in
AML/CFT
International Advanced
Certificate in
Anti Money Laundering
2.2 Malaysia: Certification (Advanced Certificate)
Completion of an Advanced Certificate whilst a recognised stand-alone qualification in its own right, does
not lead to full Professional Membership of the ICA. Should you wish to move towards this status, you will
need to embark upon study for the Diploma level programme. Note, however, that study of either of these
programmes is good preparation for those intending to move on to the next level.
Further information on each of these courses and levels of membership can be found on the ICA website at
http://www.int-comp.org/certificates-diplomas and http://www.int-comp.org/Membership or IBBM website at
www.ibbm.org.my/certification
2.3 Malaysia: Advanced Certification (Diploma Programme)
All Diploma programmes are Graduate level. Completion of a diploma level course leads to full professional
membership of the ICA. This is explained in more detail under the ‘Professional Recognition’ section below.
2.4 Malaysia: Certified Professional (Post Graduate Programme)
The Malaysian Certified Professional designation (CP) is a post-graduate programme for experienced
practitioners and leads to fellowship status of the ICA.
4
Part 1: Introduction
3. The Training Approach
3.1 Overview
The Advanced Certification and Certified Professional programmes are scheduled for completion over 9 – 12
months, i.e. a full academic year, whilst Advanced Certificates can be completed over 4 – 6 months.
These timeframes allow delegates sufficient opportunity to fully explore the issues covered by the
programmes, undertake self-study, complete the assignments (where required), attend workshops and
prepare for the end-of-course examination.
3.2 Integrated learning
ICA/IBBM programmes are delivered through a unique combination of high quality course materials studied
by delegates via distance learning, supported by first class website facilities and combined with the option
of regular face-to-face workshops facilitated by experienced industry professionals. This approach, known
as Integrated Learning, offers an excellent opportunity for delegates wishing to participate in a quality
study programme in a manner which is both practical and designed to maximise learning. The format
of the programmes ensure that study can be fitted around work and home commitments, whilst the
minimal number of days out of the office necessary means neither employees nor employers are greatly
inconvenienced by extended periods away.
4. Workshop Based Programme Format
4.1 Overview
This is the main route to attainment of the ICA/IBBM Qualifications and is offered wherever possible. The
purpose of the workshop environment is to explore the topics covered within the course materials in a
practical way that is clear and which effectively brings them to life for delegates. Using a case study format,
the industry-experienced tutor who leads each workshop will explore different subject related issues,
allowing plenty of opportunity for discussion and clarification. They will provide examples throughout and
explain relevant terms to ensure understanding.
Workshops also provide delegates with a good opportunity to liaise with their peers, discuss approaches to
study and generally ensure they are comfortable with the topics covered.
In undertaking study via the Workshop Based route delegates:

receive all core manuals and texts via the website
access the website and all support information
have access to an online tutor on an ongoing basis
attend workshops
submit assignments
are assessed through a combination of the assignments and an end-of-course examination.
4.2 Timetable
The dates, locations and timings for workshops are provided when delegates embark upon their studies and
these should be scheduled in accordingly.
4.3 Format
Full details of the delivery format for each programme are set out in the relevant Course Guide, whilst
relevant workshop dates for each programme are available on the website.
The combination of workshop days differs dependent upon the programme enrolled upon, please refer to
the relevant course for full details.
5
For example:

The Certification Programme is usually delivered over two days or four half-days.
The Advanced Certification (diploma) is delivered via four one-day workshops scheduled at intervals
throughout the programme.
The Certified Professional (post-graduate diploma) is normally delivered by six half-day masterclasses.
The workshops are held in a variety of locations in Malaysia, subject to a minimal number. The workshops/
masterclasses explore the topics covered by the Units in the order they are set out within the Core Text. It is
important, therefore, that delegates study the programme text in sequence.
5.
Student Membership of the ICA
When delegates enrol upon an ICA/IBBM programme they are designated a Student Member of the ICA. The
membership will last for the duration of the period of study.
During this period, all Student Members can access the following on-line support package:

6.
updates on national and international anti money laundering, financial crime prevention and
compliance issues
information exchange enabling members to exchange ideas, views, problems and information
FAQ’s relating to the Education Programme and the ICA
courses, conferences and events information (with details of discounts for members)
past examination papers and answer guides
useful links to industry related sites
international news service
international databases of laws, regulations and practices ensuring up-to-date and relevant industry
specific information
receive copies of InCompliance, the quarterly on-line journal of the ICA.
Professional Recognition
Full professional members of ICA are required to demonstrate strict levels of competence in their chosen
discipline of compliance, anti money laundering or financial crime prevention. This is normally evidenced
through successful completion of the ICA Diploma. Professional Membership of the ICA indicates a high
level of practical competence in the field of international compliance, financial crime prevention or anti
money laundering practice.
Once delegates have successfully completed Diploma studies they are invited to join the ICA as a full
Professional Member and use the designation ‘MICA’ (Member of the International Compliance Association).
After five years professional experience Professional Members can apply for Fellowship (FICA). Further details
of how to do this can be found on the ICA website.
6
Part 2:
Study Approach and Requirements
Part 2:
Study Approach and Requirements
1.
Welcome to the Programmes
When you enrol you will receive a welcome letter. This provides details of your username and password that
enable you to access the websites and the information you should utilise alongside your course materials.
Website access provides you with the opportunity to view thousands of pages of relevant information, access
to many pages of additional source material and to begin familiarising yourself with the issues that will be
covered during your studies This information supports the information in your course materials. The course
materials will be your main academic and learning tool. Alongside these, this Handbook will ensure you are
familiar with all relevant academic and administrative procedures and requirements.
Take time to read through the following sections carefully to ensure you understand all you need to be
familiar with during your period of study.
2.
Course Materials
The range and level of study materials available to delegates is dependent upon the level and format of the
programme studied. These are explained in more detail below.
2.1 Delivery
The study materials are available on the study platform at or around the closing enrolment date.1 For those
studying at Certification or Advanced Certification level, these will consist of the following:

Core Text manual (online format)
Appendices (if applicable for that programme)
Study Handbook
Workshop Information
Any support texts
Webinars.
2.2 Usage
Your course materials form the basis of your studies and you should ensure you are familiar with them. How
to utilise these to best effect is explained in detail in the Course Guide set out at the beginning of the Course
Text for your particular programme.
At this stage it is important to understand that the course materials comprise only one aspect of the
integrated learning approach and to obtain full benefit from your studies you should also make use of the
different elements within the ICA and ICT websites, the discussions and materials provided during the
face-to-face workshops and of course the guidance of your tutor, assigned by ICT.
1.
Course materials are updated annually just prior to the main programme intake date. Note that where delegates enrol on programmes well in
advance of this date they will be provided with the existing materials and an updated version will be sent through to them automatically once
these are available.
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2.3 Updates
All materials are updated annually. Delegates are encouraged to access the ICA and ICT websites regularly to
ensure they keep abreast of industry developments. In addition, key developments will be discussed within
the workshop environment.
Note that if delegates enrol on programmes just as an updated set of materials are being finalised they will
be provided initially with an existing online set and subsequently supplied with a copy of the updated online
version once these are available, provided these are available before the closing date for that programme.
3. Getting Started
3.1 Course Guide
Before starting work on the course materials you should read through the Course Guide set out at the
beginning of the course text. This contains important information and guidance on different aspects of
your programme:

Course Materials
Assessment Requirements
Website Information
Tutor and Administration Support.
The Course Guide explains how the different aspects of the programme fit together, how these should be
utilised and how these are intended to support you in your studies.
3.2 General Guidance
Some points to take into consideration when planning your study:

4.
We recommend 6-8 hours of study per week for those studying at Advanced Certification level and
4 – 6 hours for those studying at Certification level but this may vary according to background,
experience, etc. Do not underestimate the amount of time required to read and thoroughly
understand the course material.
You should concentrate on the course text as your main source of information, but utilise the website
to keep abreast of industry developments.
Each unit has ‘Learning Objectives’ set out at the start and ‘Unit Outcomes’ at the end. These are your
main guidelines as to what you should achieve from each unit and particularly what you should be
able to do by the end of the unit. In between there are ‘Self-assessment Questions’ (SAQs) and ‘Tasks’.
Answers to the SAQs are set out at the back of the Course Text.
If you are at all uncertain about the answers to the self-assessment questions you should study that
unit further before moving on to the next one.
The practical tasks are there to provide obvious linkage between study and your day-to-day work,
e.g. reviewing legislation and its application to a particular point in the text.
You will also encounter examples and case studies. Almost without realising it you will become
familiar with the most important cases because of repetition. It is important that you understand the
principles and are able to apply them in factual situations.
The Websites
The ICA and ICT websites are an essential ingredient in the study programme framework. Understanding
how these work and what information they hold will be invaluable to you in your studies.
4.1 Introduction
You will be issued with a Username and Password when you enrol on your course. This will allow you access
to our two websites:
10
The two sites should be used in conjunction with each other. Essentially, the ICA site is the library and
information site whilst the ICT site contains support and testing information relating to your particular course.
When you log into either site you will automatically be taken to ‘your homepage’ on the ICT website. If you
wish to navigate back to the ICA website you will need to click on ‘visit ICA website’.
So what will you find on each site? Here are some key content areas:

Both sites have an up-to-the-minute news-feed on their home pages. This news-feed is automated
and scours news providers from around the world for anything related to compliance, anti-money
laundering, fraud, corruption etc.
Both sites also have information on courses, course dates and locations, frequently asked questions
on money laundering, financial crime and compliance, comprehensive and continually growing links
sections to regulators, law enforcement, associations, law libraries, industry news providers and more.
The content and function of each website is explained in further detail in the following two pages, together
with details of how to access and utilise the sites to best effect.
4.2 How to Use the ICA Website
The International Compliance Association site www.int-comp.org is the library and information site where
you will find the support materials for your course-work.
11
The ICA site holds the Members Only section which includes the following:

12
The On-line Resource Centre which includes a number of sub-categories such as:

Corporate Governance and Corporate Social Responsibility

International Initiatives, Basel, European Union and the Council of Europe, FATF, IMF and World
Bank, IOSCO, OECD, United Nations, Wolfsberg Group and regional initiatives etc.

Basel II and III

National Legislation for over 80 countries, with links to further information

Corporate Social Responsibility

The National Legislation area of the ICA site is packed full of laws and regulations that affect
your jurisdiction, but events can move very fast in each country so it is advisable to check and
see if there is any recent legislation with your local regulator/legislator. These links are provided
for your convenience in each country’s section.
The Knowledge Bank holds a variety of articles and information including sections on:

Cases, Examples and Methodology

Corruption

Fraud

KYC/Client Due Diligence

Risk

UK Actions and Articles, FSA Updates

USA Actions and Articles, including OFAC updates and more

Miscellaneous section which has various articles, speeches, publications and links on terrorist
financing etc.
A Discussion Forum where you can ask questions, bounce ideas off your peers, ask for guidance, seek
help from fellow members, share experiences, knowledge, best practice etc.
An E-mail Alert service where you can select categories of the site you wish to be updated on – it is
important to check back to this area as new categories/sections added subsequently will not be included
in your selection. If your email storage space is limited we suggest you select the ‘Plain Text’ version.
An Updates section, which includes:

News Updates: Latest news and regulatory updates from groups like the FATF, OECD and the
US Treasury etc.

Members’ News and Announcements

Special Offers: A selection of ICA members’ discounts to various conferences, events
and publications

Discussion Forum: Keep track of the latest conversations in the discussion forum

This area also includes a Members’ Directory, where you are able to look up details up fellow
members from around the world once you are a full ICA member

Bookshop – order relevant titles at reasonable rates.
4.3 How to Use the ICT Website

Home

About ICT

Qualifications

Contact

Site map
International Compliance Training (ICT) is the
exclusive training arm of the International
Compliance Association. We offer certificated
professional qualifications in the fields of
anti money laundering, compliance and
financial crime prevention. For beginners
and experienced practitioners alike, our
certificate and diploma qualifications increase
knowledge, improve skills and enhance
understanding.
--AWAITING MORE TEXT--
INTERNATIONAL NEWS
 Ex-Thai PM Thaksin, Wife To Testify In Corruption Case:Lawyer
Morningstar.com 30 Apr 2008 09:05:17 UTC
 Marcel Berlins on electoral fraud in the UK
Guardian Unlimited 30 Apr 2008 09:04:09 UTC
 Internal Siemens probe uncovers widespread corruption: company
Yahoo! Canada 30 Apr 2008 09:01:32 UTC
 Other UK Business: Supermarkets facing new code of practice
Birmingham Post 30 Apr 2008 09:00:47 UTC
 Independent News chairman is named on board of Central Bank
Eircom.net 30 Apr 2008 09:00:36 UTC
1 - 5 Next site www.int-comp.com gives you online access to your study
The International Compliance Training
International Compliance Training Ltd 2008 | Terms and Conditions
programme and includes thefollowing
important areas plus many others you will find of interest:

5.
Course Diary: This lists all of your important course dates, such as assignment due dates, examination
dates, workshop dates (if applicable)
Assignments: download your assignment questions and feedback
Syllabus: a breakdown of each unit in your programme
Self Assessment Questions: additional SAQs to allow you to test your knowledge on each unit and
learn more with the answers
Specimen Exam Papers and Questions: an example of the examinations set to help you prepare for
the actual examination
Student Support: ask questions to your tutor or the Admin Team online
Appendices and Further Readings: download these additional course materials
Assessment results: view your assignment/examination results online
How to...Guides: a series of visual guides on how to approach assignments/exams etc.
Chief Examiner’s Reports: view reports from previous years examination
Pre-recorded webinars: download these subject specific webinars as part of your course.
Tutors
When you enrol on your course you will have access to a tutor via email, although you can raise more
general queries online in the Discussion Forum as referred to in the previous section.
The Course Tutor is the individual to whom you should address any queries or questions you have
regarding your studies and who will be able to discuss any relevant aspect of the materials with you.
However, all administration related issues should be raised directly with the ICT Administration team via
email [email protected].
13
You may contact a tutor at any time via email. When doing so, please email [email protected]. The
administration team will then forward your query to the appropriate tutor and they will ensure that your
query is responded to promptly.
6. Programme Content – Workshops and Workbooks
6.1 Briefing/Induction Sessions
At the beginning of the course you will either have attended or viewed on the ICA website a Briefing session
that is designed to help you get started and introduce you to the programme you are embarking upon.
This introductory session focuses on:

The course overview
Review of the course materials
Administration
Study techniques
Assignment preparation techniques.
If you have not already done so, please view the session before commencing study – you can find this via
the ICT website. During the first workshop you will also cover these topics in detail to ensure understanding,
whilst those studying via the Distance Learning only format of this programme can access focussed webinars
on these topics, again on the ICT website.
6.2 Workshops
The face-to-face Workshop format is the usual means by which delegates study for ICA qualifications. If you
are studying via the Workshop format, details of when these workshops are scheduled will be confirmed
with your materials. Details of the specific units/topics to be covered can be found on the ICT website under
workshop preparations.
Workshops are scheduled at suitable intervals throughout your period of study and will enable you to
discuss any aspect of the course with an experienced industry professional.
The workshop sessions are designed to:

expand and review substantial knowledge
enhance practical awareness
create the ability to deal with the more difficult areas of the syllabus
analyse problems in a practical context
develop the examination techniques necessary to succeed
allow you to interact with your peers studying the same programme.
The workshops comprise a variety of discussions, case studies and exercises addressing key areas of the
course syllabus. It is not possible to explore each and every area of the syllabus within the workshop
environment; therefore the course tutors prepare these sessions to focus on important issues and topics.
6.3 Workshop Handouts
When you attend each workshop you will be provided with an additional workshop pack containing a copy of the
slides used by the tutor during the session, together with additional supporting handouts. These can be used to
aid your note taking and revision of the topics covered during the workshop session.
Although you will be provided with copies of the slides used during the workshop, you will need to make your
own notes on the day. These do not need to be detailed but should summarise the key issues you have identified
14
as needing your attention during your revision of the topics covered. It is important that you do take notes, as
these are most valuable to you when you commence revision and preparation for the examination.
If you are unable to attend a workshop for whatever reason and are unable to transfer to a suitable alternative
date, a copy of the workshop pack will be forwarded to you and you will be able to raise any queries you have
regarding these and the topics covered during the workshop with your tutor via email in the usual way.
6.4 Revision and Exam Preparation Session
The revision and exam preparation session included as part of the final workshop for the Certification and
Advanced Certification programmes provides a summary of key points covered during previous workshops
and also focuses on a variety of approaches to aid delegates as they prepare for their examination.
7.
Study Groups
Study groups are a positive way of taking some of the ‘distance’ out of the distance learning aspect of
the programme. Once you have enrolled onto the course you will receive an email invitation to join a
study group on ‘LinkedIn’. LinkedIn is an online network for professionals and, if you are not already
signed up, is quick and easy to join. There is no obligation for you to join the online study group but many
delegates find that it is a fun and informal way to keep in touch with fellow students, discuss aspects of the
course and share experiences. Some delegates even arrange to meet face to face if convenient. If you want
to find out more information about LinkedIn or forming a study group then contact us on [email protected]
or +44(0)121 362 7653.
8. Mentor Scheme
8.1 Overview
Some delegates might wish to have a Mentor to assist them in their studies. This is an individual decision,
not a formal part of the programme and it is not therefore mandatory to have a Mentor.
A mentor is ideally, though not necessarily, a person who is experienced in the area of work that
the delegate is studying, e.g. a line manager, colleague or friend. The mentor’s function is to give
encouragement, motivation, help and guidance throughout the duration of the course.
You may not require or desire the assistance of a mentor and it is not a requirement of you completing the
course. However, you may want informal support from someone who may know you well, who has studied a
similar course or perhaps has a great deal of experience and is a good motivator.
8.2 What does the mentor do?
The key role is:

to review the course structure, format and examination with you as outlined in the course documentation
to discuss the format, style and requirements of the examination
to work out with you a course plan, study sessions, preparation, mentor meetings, revision sessions
and examination preparation
to assist and guide you with the course materials and schedule
to provide hands on practical experience on work based tasks
to provide a personal tutor role of encouragement and support.
Ideally the mentor should also be able to:

assist with time management, permitting you some flexibility to facilitate study periods,
e.g. allowing you to work through lunch time and finish early so that a visit to the library can
be arranged

allow flexibility in terms of booking leave to fit in with study and examination arrangements

allow access to terminals with website facilities where this is not already available in
the workplace.
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Part 3:
Assessment
Part 3:
Assessment
1.
Introduction
The assessment method is dependent upon the level and format of the programme studied, as follows:

Certification (advanced certificate) level programmes are assessed through submission of one
assignment and an end of course examination
Advanced Certification (diploma) delegates are assessed through submission of two assignments and
completion of an examination at the end of the course.
Certified Professional (Post-graduate) level delegates are tested through a face to face oral
interview/assessment.
The different methods of assessment are designed to offer delegates the broadest possible opportunity to
demonstrate their understanding of the topics studied at whichever level they are studying. Set out below is
some further information on each of these different methods.
2. Assignments
2.1 Timetable
You will be required to complete one assignment as part of the programme if you are studying at
Certification level, whilst those studying at Advanced Certification level complete two. When you enrol on
the programme you will be advised of the date(s) on which these are due for submission.
2.2 Format
When you receive your course materials and website access, you will be able to download each assignment
question from the ICT website three months before the submission due date.
2.3 Purpose
Assignment questions are structured and phrased in a particular way in order to stimulate enquiry, thought
and research on the part of the delegate, linked to the topics they have studied. Assignments skills to be
assessed relate specifically to the ability to demonstrate knowledge and understanding at the required
level, combined with the ability to apply these to the question set and providing evidence of the ability to
research and explore issues in sufficient detail.
2.4 Coverage
The submission dates for the assignments are scheduled at key points within the overall programme
framework, requiring delegates to base their work on the portion of the programme they have covered
at that point. Further guidance on the scheduling of these in conjunction with self-study, attendance at
workshops or completion of Distance Learning Workbooks is detailed in the Course Guide at the front of the
relevant course materials.
2.5 Question Style
The style of question set is normally “case study” or “essay style”. The first of these sets out a scenario on
which the delegate is to base their answer, drawing on their studies around the topic, whilst the second
is broader and requires the delegate to demonstrate clearly an ability to assess the requirements of the
question and structure their answer to ensure they address these.
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The different styles will be discussed and explored during the Induction and Revision sessions, and as part
of the Workshop and Distance Only workbook formats. Further guidance is also available as part of the
pre-recorded Webinar series.
2.6 Approach to assignment writing
For many delegates, the requirement to complete assignments whilst studying for these programmes will
be the first occasion in some time where they have been required to undertake a task of this nature. Some
can therefore find this potentially daunting. For this reason, every effort is made to provide guidance and
information to assist delegates and ensure they are able to focus on the main task in hand, i.e. exploring the
issues covered by the assignment and being able to demonstrate their understanding and ability to apply
their knowledge as required.
A detailed Assignment and Examination Questions Writing Guide, covering issues such as overall
approach, wording and review before submission, is attached at Appendix 1. It is recommended that all
delegates who will be completing assignments take the opportunity to read this carefully at the outset and
then again when preparing assignments for submission.
2.7 Submission
There are a number of important points to keep in mind regarding submission of assignments:
1.
2.
Assignments should be submitted via email (by no later than the specified date) to:
[email protected].
Assignments are required to be submitted in a certain style and in a certain format, as
summarised below:

3.
4.
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assignments must be submitted by email
should be between 2500-3500 words (excluding appendices and bibliography but including
footnotes – all of these should however be reasonably in keeping with the paper and not
overshadow the body of the text)
print should be font size 12
use 1.5 spacing (to aid marking)
save your assignment as your ICA delegate number e.g. 3704543 as one document only, in a
Microsoft word format
DO NOT write your name anywhere on the assignment
ensure you state your industry sector on the assignment. For example Banking, Insurance, Law
Enforcement, Regulator, etc.
ensure that you state the programme and the question number that you are attempting at the
top of your assignment e.g. ‘Advanced Certification (Diploma) in AML/CFT – Assignment 2’
include your ICA delegate ID number in the header section of each page
ensure you paginate your assignment.
When you submit your assignment, you must confirm in your email, that this assignment represents
all your own work by the inclusion of the phrase “I confirm that this assignment represents my own
work and where quotations and/or ideas have been utilised from other sources these have been
acknowledged and referenced accordingly”.
When an assignment is received, the ICT administration team will email delegates to confirm receipt. If
a response confirming receipt is not received within 24 hours (please allow longer if over a weekend),
you should contact ICT accordingly. Failure to receive a confirmation means that the ICT administration
team has not received your assignment, so it is important that delegates ensure these have been
submitted and received by the ICT team by checking that a confirmation has been received.
Part 3: Assessment
2.8 The marking process
Markers work to a detailed Assignment Marking Guide and also consider the guidance set out in Appendix
2. You should familiarise yourself with the information in Appendix 2 in order to understand the marking
range and focus on content and structure.
The assignments are forwarded to the first marker for detailed review and comment. Assignments are
marked out of 100. All assignments achieving more than 70% or less than 50%, together with a percentage
of all assignments initially graded between 51-69%, are automatically independently re-marked by a second
marker. All assignments achieving less than 50% or above 70% at the second marking are then examined by
a third marker, prior to the final marking being agreed by the internal marking team.
With hundreds of assignments being marked at any one time, this process can be time consuming. A
seven-week marking period (from the assignment due date), to comprise first, second and third marking
plus the final review and all administration stages, is therefore strictly adhered to.
2.9 Extension requests
All extension requests are at the discretion of the Course Director of the programme. However, the following
flowchart sets out the approach taken re these.
If you feel that you are in an unavoidable situation where you cannot submit your assignment on time
please put your request in writing to the Administration Team – [email protected]. Your request will be
forwarded to a Course Director for consideration.

Extension
request
received

Are you making your request on the due date? Extension requests received on
the due date itself will be automatically refused.
Please refer to the section below on the Penalty Scheme applicable. See also
option 2 in the section below.
Extenuating circumstances? For example:

Before
due
date?

No
extenuating
circumstances?

major ill health supported by a Doctor’s certificate
a major family crisis such as a recent bereavement/children’s or partners
major illness
extremely unexpected emergency travel connected with employment
(employer’s confirmation would be required)
regulatory spot check visit (i.e. not pre notified or planned) – employer
confirmation required
if yes you may be offered one month extension or deferral – see options below
N.B. Pressure of work/travel/holiday or simply running out of time do not
constitute extenuating circumstances.
A check will be made for previous extensions (only 1 extension based on
extenuating circumstances is allowed per delegate per course) – if you have
already received a previous extension for this course then your request will be
automatically refused and you will be offered a deferral – see option 3. below.
If no extenuating circumstances or previous extensions see options 1. 2. 3.
and 4. below.
21
There are 4 possible options:
1.
2.
No
previous
extensions
3.
4.
Submit on due date (remember the Penalty Scheme applies if you submit after the
due date without an approved extension – see below for penalty scheme details).
Take the penalty – the initial penalty is 5%. Your paper must then be submitted
within 10 days of the original due date. Assignments received more than 10
days after the original deadline incur an additional penalty of 2% per day up to
a period of 20 days. No assignment will be accepted more than 20 days after the
original submission date. NB results will be issued 11 weeks after the original
due date.
Defer to next appropriate assignment(s) NB this will in effect extend the overall
length of your course and exam results will not be released until all assignments
are completed.
Refer via email to ICT Admin at [email protected] for an extraordinary one
month extension (i.e, not due to extenuating circumstances as above) these are
extremely rare and at the Course Director’s discretion. Any extensions granted are
for a fixed period of one month and the results will be 7 weeks after the new due
date and may not be available very far ahead of the next submission date to allow
you to benefit from the feedback. This is NOT a recommended course of action.
2.10Assignment penalty scheme for late or non-submission
The ICA operates a penalty scheme for late or non-submission of assignments. The aim of this scheme is to:
a)
b)
discourage late submission of assignments and to ensure fairness in the procedures, and
enable the administration team to manage the workload effectively as a volume-based batch
processing system.
In summary, assignments submitted late will incur a penalty as follows:

The initial penalty will be 5% and delegates must then submit their assignment within 10 days of the
original deadline date.
Assignments received more than 10 days after the original deadline will incur an additional penalty
of 2% per day up to a period of 20 days. No assignment will be accepted more than 20 days after the
original submission date.
If you do find yourself in an unavoidable situation where you cannot submit your assignment on time
please contact one of the administration team for further advice in advance of the due submission
date. Your request will be referred to the Course Director who will assess each application on an
individual basis. Please note that requests for extensions received on the assignment due date will
not be granted.
Any assignment that is received late, i.e. within the 20 days, will be included with the extensions and the
marks released accordingly. Extension dates are set at a standard one calendar month after the due date and
the results released 7 weeks after the extension date.
Please note that this scheme excludes those assignments that have received a formal extension, as referred
to above, which must be submitted within the timeframe agreed.
2.11Assignment results
The marking timeframe for assignments is 7 weeks from the submission date and your result will be posted to
your personal Homepage of the ICT website at the end of this period. You will need to log on to access your
marks which will show at the bottom of the page and click on the link provided to view your Individual Feedback.
22
Part 3: Assessment
For Advanced Certification delegates, when both assignments have been completed the marks are added
together and averaged to determine your overall assignment mark, which represents 50% of your final
assessment result with the other 50% achieved in the examination.
2.12Feedback
An overall summary of some of the key points and issues that delegates could have included in their
assignment will also be provided when the Assignment results are issued. This General Feedback will be
posted to the Assignment section of your course programme once the results have been released.
2.13Referencing and plagiarism
Failure to properly reference is, together with plagiarism, taken extremely seriously. It is vital therefore that
you understand why it is important to properly reference when producing your assignments and how to
do this.
Whenever using the ideas and/or phrases/words of another to support points made within your own work –
an approach that is actively encouraged – you must take care to reference where you have obtained them.
Failure to do so means you are effectively putting forward another’s work as your own – this is known as
plagiarism and is unacceptable. It is therefore important to clearly reference any such work to ensure tat the
source of the work is apparent.
When markers look at references, their aim is to be able to reconstruct where you obtained your material.
You need to supply sufficient information to enable the reader to be able to do this and locate the exact
reference you have cited.
There are two main methods of referencing and these are set out in Appendix 3. Please read this carefully
to ensure you are referencing satisfactorily when preparing your assignments or answers in examinations.
Adopt the format set out in the appendix and your approach to referencing will be clear.
2.14Appeals
Please note that appeals cannot be made on individual assignments. An appeal can only be made once you
have received your final assessment results, which are released 8 weeks after the examination and providing
the assignment component has been completed. Please refer to 3.12 for further information on this.
3. Examination
3.1 Timetable
All Advanced Certification and Certification programmes require delegates to sit an end of course
examination as part of the assessment process.
3.2 Coverage
The examination paper draws from all of the topics covered by the course syllabus.
3.3 Format
Examinations are normally of 3 hour 15 minute duration for Advanced Certification programmes, 1 hour and
45 minutes for Certification programmes. The first 15 minutes is for reading only, during which candidates
may not commence answering questions. However, they can and should use this time to select their
question options and may therefore write on the question paper only.
3.4 Purpose
The purpose of the examination is to assess the candidates’ knowledge and understanding of the topics
covered throughout the course and their ability to demonstrate application of this knowledge and
understanding within a specified timeframe in response to the questions set.
23
3.5 Question Style
Advanced Certification programme candidates are required to select four from the seven questions
contained within the paper, whilst Certification candidates select two from five.
These are presented in essay/problem/case study format and span topics covered across the syllabus. Where
appropriate, you should cite legislation, case authorities and practices to support your answers.
The examination tests your ability to identify relevant issues, explain basic principles and apply detailed
knowledge gained from your studies to any given factual situation. Analysis is important. Credit will be given
for well-reasoned analysis of issues and legal principles even if a conclusion is incorrect.
Further guidance on Examination preparation is set out in Appendix 4. You should read this carefully before
the examination.
3.6 Entry fees
No separate entry fee for the examination is payable once you have registered for the programme. No
separate examination fee is payable to re-take the examination on one single occasions (per paper). In the
event of any further re-taking of the examination you may be required to pay an additional fee.
3.7 Illness and special considerations
If you are impaired or injured prior to an examination and require a special facility at the examination you
should notify the local IBBM and ICT Administration Team prior to the examination ([email protected]) and
[email protected]. Additional time may be given if you are impaired through illness or injury.
If, as a result of your illness, injury or other exceptional circumstances, you consider that your performance in the
examination will be adversely affected you may apply to ICT, through the Administration team, for consideration
to be shown. Where appropriate such application should be accompanied by relevant documentation e.g., a
medical certificate, to be sent to the Administration Team as soon as possible before the examination.
3.8 Marking process
The marking timeframe is 8 weeks and as with Assignments, examination scripts are marked according to a
strict timetable. The examination and final assessment results will be posted to the ICT website and will be
shown on the delegate's Homepage.
Please note that the final assessment result (which includes the examination mark) can only be confirmed
once all assignments have been marked.
3.9 Examination mark and final assessment results
Once examinations have taken place, the examination mark is added to the overall assignment mark and
averaged to determine the final assessment result. When these marks have been finalised and agreed by the
Examination Committee and Test Board, the results will be posted to the ICT website and will appear on the
delegate Homepage as Exam Mark and Final Mark.
Those who have achieved a Pass, Merit or Distinction grade at Advanced Certification (Diploma) level or
Certification level (dependent upon the programme studied) will be issued with the International Diploma
or Advanced Certificate.
3.10Pass marks and allowances
The overall assignment and examination marks are added together and averaged to determine the Final
Assessment Result. The pass mark is 50, however, if either the overall assignment or examination mark is
below 40, this will be deemed as a Fail and this element will need to be retaken. In such cases, delegates will
be contacted individually to discuss necessary next steps.
24
Part 3: Assessment
3.11Issue of Certificates
All Certifications will be presented to delegates at an Award Ceremony held in Kuala Lumpur annually.
Details of planned Award Ceremonies will be posted online. For those delegates unable to attend the
Ceremony, these will be posted shortly after this event.
The overall Advanced Certification (Diploma) award will be classified in accordance with the following list:

Diploma with Distinction (70+)
Diploma with Merit (60-69)
Diploma Pass (50-59)
Diploma Examination Mark
Grade
Level of Achievement
70+
A
A first class paper – Distinction level
60 – 69
B
Good Pass – Merit level
50 – 59
C
Satisfactory pass – Pass level
40 – 49
D
Marginal Fail – Marginal fail level
39 or below
F
Fail – Fail level
Those who have achieved a Pass, Merit or Distinction grade in the Certification programme will be issued
with the Advanced Certificate, which will be presented at the ceremony after they have been shown on the
delegate‘s Homepage.
The overall Certification (Advanced Certificate) award will be classified in accordance with the following list:

Advanced Certificate with Distinction (70+)
Advanced Certificate with Merit (60-69)
Advanced Certificate Pass (50-59)
Advanced Certificate Examination Mark
Grade
Level of Achievement
70+
A
A first class paper – Distinction level
60 – 69
B
Good Pass – Merit level
50 – 59
C
Satisfactory pass – Pass level
40 – 49
D
Marginal Fail – Marginal fail level
39 or below
F
Fail – Fail level
3.12Appeals
There is no provision for appeal against the academic judgement of the assessors. An application for a
review may be made only on grounds alleging:

that there exist or existed circumstances affecting the delegate’s performance of which the assessors
had not been made aware when the decision was taken
that there was procedural irregularities in the assessment process
that there is evidence of prejudice or bias or of inadequate assessment on the part of one or more of
the assessors.
Delegates wishing to appeal on these grounds must do so in writing, addressed to the Examination Board
and submitted via the central administration.
25
Where delegates have been awarded a Failing Grade for any assignment (50% or less) they will need to liaise
directly with the Course Director to discuss next steps.
Further examination protocol is covered in Appendix 5. You should be familiar with the content of this
before attending your examination.
4. Course Feedback
4.1 End of workshop
Where you attend workshops as part of your study programme you will be asked to complete a
questionnaire covering many different aspects of the workshop. These are used to assess how effective
different aspects of the workshop have been and provide delegates with the opportunity to provide
feedback on any issues they would like to raise.
4.2 End of course
Enclosed with the confirmation of results letter for all our programmes is our end of course assessment form
and we would be grateful if you could complete this in order to provide us with your feedback. Your views
are of interest to us and we make every endeavour to ensure our courses maintain their high quality through
adoption of delegate feedback.
26
Part 4:
Administration
Part 4:
Administration
1.
Contact Details
Administrative Office
Institut Bank-Bank Malaysia
Wisma IBI
No. 5 Jalan Semantan
Damansara Heights
50490 Kuala Lumpur
Telephone: 603–20938803
Fax:
603–20952322
Email:
[email protected]
For general enquiries regarding your course, materials or any queries relating to your studies, venue
arrangements, workshops or examination, please contact the IBBM Administration Team.
Assignments should be emailed to [email protected]. All assignments will be sent a confirmation
of receipt, which should be retained as proof in case a problem occurs after the submission date. If receipt
has not been confirmed, please contact the administration team.
For enquiries regarding membership benefits or website access, please contact the ICA Administration Team
at [email protected].
2.
Terms and Conditions
IBBM reserves the right to cancel a workshop, where the occasion necessitates. IBBM accept no liability if, for
whatever reason, a workshop does not take place.
All programmes must normally be completed within two years from the course start date.
IBBM requires full payment of course fees with the enrolment form, prior to the commencement of the course.
Payment should normally accompany the enrolment form unless otherwise agreed with the Administration
team. Delegates will not be permitted to attend the workshops or receive exam results if payment is outstanding.
Delegates are permitted one examination re-sit free of charge. After that, the examination re-sit fee is RM200.
3.
Refunds
If a delegate withdraws from the programme before the issuance of the Username & Password, the delegate
will be refunded the programme fee less a charge of RM200.
If a delegate withdraws from the programme after the issuance of the Username & Password but before his/
her scheduled first workshop date, the delegate will be refunded only 50% of the course fee. No withdrawals
are allowed after this period.
If a delegate fails to attend a workshop or examination, no refund will be paid.
29
4.
Deferrals
If a delegate defers the programme before his/her scheduled first workshop date, no additional cost will
be incurred.
If a delegate defers the programme any time from his/her scheduled first workshop date, the delegate must
pay a deferral fee of 25% of the programme fee. This deferral is only valid for the next immediate intake.
5.
Data Protection
The information you have provided will be used by the ICA/IBBM or approved agents for administrative,
membership and educational purposes or as required by law.
If you do not want to receive mailings from third parties, please let us know by emailing us at [email protected].
30
Part 5:
Appendices
Appendix 1:
Assignment and Examination Questions
Writing Guide
1.
Introduction
Whatever the assignment style, whether essay, case study analysis, report or memorandum writing, it is
not uncommon to approach such activity with trepidation. No doubt this is due to the sheer volume of
work involved – gathering and organising information and presenting an argument or because it has
been some time since you have attempted such an activity or because the context of study is new and the
boundaries uncharted.
This guide is designed to help you focus on the key issues involved and to develop your skills in analysis,
interpretation and expression. The key principles outlined can be used for all types of assignment writing,
whether at Certification or Advanced Certification level.
Always remember that there is no such thing as a model answer to an assignment in that there can often be
many different approaches to an assignment question all of which are equally valid. There can be a number
of suggested solutions all of which may attract high marks.
2. Analysing the Question
2.1 Determine the scope of the question

A question is worded to guide you towards answering in a particular way and using particular types
of material.
The question may be made up of one or more parts.
Make sure that you determine how many areas have to be addressed in your answer.
You may find it useful to paraphrase the question in your own words.
Consider what weight you might be expected to give to each section.
Determine the limits/parameters of the question. E.g., it may direct you towards a specific topic/s,
situations, general principles or jurisdiction specific issues.
The material you use in your answer will be only that which falls within the scope of the question:
anything else would be considered irrelevant. Never include information just because you think it is
interesting or sounds good: if it is not relevant to the question, it will lose you marks.
2.2 Identify Key Words
Before you think about rushing off to find material, think carefully about what the question is actually
asking. Underline key words and make certain that you understand their meaning. Key words indicate both
the content and the processes or methods to be used in answering the question.
2.3 Key words in terms of content
Question: ‘Describe and evaluate the different AML/CFT compliance strategies employed in a small organisation
of your choice’.
Many terms used in questions require some thought to determine our understanding of them. For example
in a question concerning compliance strategies used to enable an organisation to ‘reach its full potential’,
what do you understand this term to mean? In a question concerning the role of a compliance officer
in identifying and managing ‘risk’ in the business, what do you understand by the term ‘risk’. Will you be
33
considering all types of risk or will you be focusing on particular types of risk? In such instances where key
words are ambiguous, it is useful to make clear in your introduction how you have interpreted the question,
and how you intend to answer it based on your interpretation.
2.4 Key words in terms of method or process
Commonly used key words which indicate method or process:
Account for: Give reasons for; example the causes of.
Analyse: Examine in details the elements or structure of; a combination of criticism and evaluation (see below).
Assess: Consider the points for and against.
Comment: State your opinions on the topic, supporting them with evidence.
Compare: Look for similarities and differences between; perhaps reach a conclusion about which is preferable.
Consider: Think carefully about, discuss.
Contrast: Consider both similarities and differences, but emphasise the differences between.
Criticise: You may be asked to criticise, or to write a critical analysis of a topic or theory. Give your
judgement about the merit of theories or opinions or about the truth of facts; back your judgement by a
discussion of the evidence or reasoning involved. To ‘criticise’ means to consider all the positive as well as all
the negative aspects of the topic.
Define: Set down the precise meaning of a word or phrase. In some cases, it may be appropriate to
examine different possible or often-used definitions.
Describe: Give a detailed or graphic account of.
Discuss: Investigate or examine by argument; sift and debate; give reasons for and against; examine
the implications.
Evaluate: Make an appraisal of the worth of something, in the light of its truth or usefulness. Criticism is
an integral part of making an evaluation, so you must criticise the evidence of textbooks, journals, other
people’s findings/research in your evaluation. Include, to a lesser degree, your personal opinion, which will
be based on the evidence you have gathered from the different materials and possibly your own research.
Examine: ‘To what extent….’ Weigh up the evidence for and against; decide how far something is valid.
Explain: Make plain or clear; interpret and account for; give reasons for.
Illustrate: Use a figure or diagram to explain or clarify, or make clear by the use of concrete samples.
Interpret: Expound the meaning of, make clear and explicit. You are usually required to give your own
judgement also.
Justify: Show adequate grounds for decisions or conclusions; answer the main objections likely to be made
to them.
Outline: Give the main features or general principles of a subject, omitting minor details and emphasising
structure and arrangement.
34
Part 5: Appendices
Review: Make a survey of, examining the subject carefully.
Summarise: Give a concise account of the main points of a matter, omitting details and examples.
Trace: Follow the development or history of a topic from a specified point of origin.
3. Collection of Relevant Materials
3.1 Purposeful reading
If you have spent time thinking about what the question is really asking, then you are more likely to
collect only that material which is relevant. Now note down all the topics/areas you have to examine, and
if possible, make out a list of questions to which you will need to find answers. Being able to focus your
attention on what is relevant to the question will save you much time: your clear view of what is required
will enable you to be more selective and focused in your choice of material, you will not waste time wading
through books and reports before realising that they offer nothing of relevance, and you will not build up
copious notes which have to be worked through at a later date to extract appropriate materials from that
which is not.
The flyleaf or publisher’s blurb of textbooks often reveals whether or not that text will contain relevant
material. If there is a preface or introduction to the text, read that too. You could also look at chapter
headings on the contents page to target the areas of the text, which are of particular relevance. If you are
unsure of a chapter’s relevance, then read the first paragraph (this often explains what is to follow in the body
of the chapter) and the last paragraph (this often summarises what the chapter was about). If the material
seems relevant, skimming rapidly through the chapter will give you an impression of what it is about.
Follow this by scanning the text. This also involves rapid reading, only this time you are on the lookout for
particular points, answers to particular questions, or specific references.
Once you think you have found material suitable for your assignment, you can return to the more normal
receptive reading at a steady, easy pace.
Finally, reflective reading should be applied, where you consider the material carefully. This type of reading is
essential for academic work as it allows you to analyse, evaluate, compare etc. When you reach the stage of
reading reflectively, you are ready to make worthwhile notes.
3.2 Specialist Reading
Ensure you read through all relevant:

Primary legislation
Regulations
Industry guidance e.g., guidance notes
Reports both domestic and trans-national
Journals, newspapers and circulars, e.g., from Government Authorities.
Familiarise yourself with your own organisation’s:

policies
guidelines
procedures
systems.
Many assignments will require you to identify, analyse and explain the compliance workings of your organisation.
35
3.3 Making Notes
When you find materials that you might use in your assignment, first note down the full bibliographical
details of that material. This ensures that you will have all the necessary information to hand when you come
to write up your references later. As you write your notes, it is useful to jot down chapter numbers or even
page numbers in the margin, just in case you might want to check up on a point at a later date. If you spot a
quotation, which might prove useful, then it is essential that you note the page number/s.
A useful technique in note making is to use colour coding. For example, notes concerning the point you
intend to make in your first paragraph could be marked with a blue stripe in the margin, those suitable for
your second point/topic of discussion could be coded red, and so on.
3.3 Academic Ethics
Plagiarism, or literary theft, occurs when students use the work of other authors in their assignments and do
not acknowledge the fact that they have done so. This not only applies to using quotations without giving
the source, but also to re-wording someone else’s ideas/findings. Using other people’s work is an essential
part of any academic work: you are expected to consult the experts! You will gain marks by incorporating
other people’s work/evidence from texts if you use it to develop/broaden/augment your own arguments.
However, you must always reference such work.
4.
Creative Thinking
In formulating your approach to the assignment:

5.
Consider why you are writing this assignment and why you are taking this approach.
What is your personal angle or “spin”?
Keeping this in mind, from reading and notes choose your main themes and arguments.
Put them in order so that they will flow.
Sort out the evidence – references, examples, and illustrations to back up your specific points.
Try to argue from the opposite point of view. Is there evidence for this?
Find the balance and some new conclusions.
Can this be developed further?
Planning
As early as possible, draft out a plan of the format you think your assignment will take. Planning an outline
of your assignment gives you a basic structure from which to work. It helps you sort out the main ideas and
the important details you will need to explain, develop or illustrate these ideas. It allows you to break down
the assignment into manageable chunks, which can later be unified.
You may find that you can devise a plan of sorts just by examining the question. Alternatively, you could
apply a brainstorming technique to the question by writing the main topic in the centre of a page and
branch out from it all the ideas worthy of consideration, which relate to the topic and would help answer
the question. These areas can then be investigated in turn, the more valid ideas being extended and the
less relevant rejected from your later plan. It may be the case that you have to carry out some preliminary
research or note taking before you can decide on your approach. Do not be rigid; you can always change
your outline. During the course of your work, some new idea or relationship may suddenly occur to you and
you will need to re-organise your original plan to include it.
Length of assignment: keep in mind your word limit. You will be penalised if your work is e.g., more that 10%
above or below the specified length. (Remember that quotations form part of your word count!) Make sure
that you allocate sufficient space and attention to the more important points.
36
Part 5: Appendices
In case study style questions you may be required to advise, comment, determine liability, issue guidelines
etc. Read the question carefully and answer the question asked. Do not be afraid to be controversial, to
specify if there is no clear answer, to leave a conclusion open or to suggest alternative answers. The key
guideline is – can I justify my conclusion?
6.
Structure or Layout
Introduction: You might explain in more detail your understanding of the question and outline the way in
which you intend to answer it. Where appropriate, you can use this section to explain the background to the
topic under discussion, to comment on the fact that the topic has perhaps caused much controversy within
certain fields, to reveal that there has been much/little research done on the topic and/or to state that there
exists a wide range of views/attitudes to this issue.
Basically, the introduction is to prepare the reader for your assignment, which will follow in the body of your
essay. It identifies key issues to be dealt with.
Main Body: This is the main part of your assignment, where you set out your material/evidence in response to
the question and discuss/evaluate/criticise it, depending on the demands of the question. Take each of your
main points and develop them with examples/evidence. Ensure that you cover all areas of the question here.
Remember, the depth to which you take your answer, the degree to which you work with your material
through analysis, criticism, evaluation, etc, the higher will be the quality of your assignment and your mark.
Conclusion: This is where you round off your argument by concluding with what you have decided or
learned, or what views you have formed, based on the new evidence and arguments set out in the body.
The conclusion should contain no new information or material, as all this should have been weighed up in
the body. To an extent, this section is like a summary of the body in that you are referring to the main points
of your argument to back up your conclusion or overall findings. Depending on the type of question, you
might suggest the wider implications, or possible lines of further investigation here.
Style: The main object is to be clear, concise and fluent so that the reader may follow your argument easily.
You are expected to write in a formal style. Do not try to impress by using unfamiliar, complicated words
and phrases, as this will show. Write instead in a straightforward manner. What you must not do is lapse into
informal style. This is the language you use when writing or conversing with friends. It tends to contain slang,
colloquialisms and to use rather simplistic expressions. As a result, it is often long-winded rather than concise.
If you imagine that you are writing for an intelligent lay reader, this may stop you lapsing into informal
expressions. (Do not imagine that you are writing for your tutor in case you assume s/he knows what you
are talking about and, as a result, you do not explain your points clearly.) Review each paragraph to see if
your meaning is clear and think about how you might relay the information in a more concise manner. Avoid
using rhetorical questions and exclamation marks.
You must always try to avoid writing in the first person i.e. ‘I think it is clear that …..’; My opinion is that ………’;
‘We ought to investigate further …….’. This gives the impression that your work is subjective and therefore
unprofessional. Turn the wording around to make your comments more objective i.e. ‘It is clear from the evidence
that …..’; ‘The evidence suggests that ……’; ‘A more thorough investigation should be undertaken/is advisable.’
Your tone should be confident; avoid giving the impression that you are unsure of the points you are
making. Words such as ‘maybe’ can indicate uncertainty. Good preparation will encourage a confident
approach to your essay. At the same time however, you must not become over-confident in your opinions.
Never generalise when making a point, as scanty evidence cannot support sweeping assumptions.
37
6.1 Paragraphing
While it is normal to take a new paragraph for each separate point, aspect or area of discussion, you must
remember that all your paragraphs are united in their purpose of answering the assignment question i.e.
they should be adding up toward some overall statement. A smooth transition from one paragraph to the
next is essential to maintain continuity of the argument by giving verbal signposts to the reader to indicate
the direction your argument is taking. Some useful linking (transitional) words and phrases to begin a new
paragraph are:

However/On the other hand/Yet/Nevertheless/In contrast to this/This is contrasted by = indicate that
the following paragraph is about to contrast what was said in the preceding paragraph.
For example/That is/This can be shown by/In addition to this = indicate that the following paragraph
is about to illustrate what was said in the preceding paragraph.
Similarly/Moreover/Furthermore/In addition to this = indicate that the following paragraph is about
to extend or continue the point or evidence given in the preceding paragraph.
Then/After that/Ultimately = indicates the next step in the progression of your investigation/argument.
As a result/Thus/To conclude/In conclusion/Therefore/ = indicate that the following paragraph is
coming to a conclusion based on what was said before.
6.2 Drafting
Never assume that your first completed version of the assignment will be good enough. Allow time to check
through for mistakes and to re-write any awkward sections. Drafting and re-drafting where necessary might
raise significantly the quality of your work (and therefore your mark). To help you do this, ensure that you
can answer YES to all the questions in the following checklist:

Have I answered the question/all parts of the question?
Have I covered the question/each part in depth?
Is all my content relevant to the questioning?
Is the content accurate?
Have I arranged the material logically?
Does the assignment move smoothly from one section to the next, from paragraph to paragraph?
Is each point supported by examples/evidence/argument?
Have I acknowledged all sources by referencing with the assignment?
Have I distinguished clearly between my own ideas and those of others (plagiarism)?
Is each reference made within the assignment supported by authority?
Have I written plainly and is each clearly explained?
Have I sorted out any clumsy or muddled phrasing? (Read it aloud to pick up awkward expression).
Have I checked through for errors in grammar, spelling and punctuation?
Is the assignment the correct length? (Too short: some important material/argument may be
missing. Too long: you may have included irrelevant material, or your expression may be rather
simplistic, repetitive and long-winded).
Is the assignment well laid out? (Check that paragraphs are not too long/short, that information is
presented in manageable, unified chunks).
6.3 Presentation

38
Work should generally be word processed, using font ‘Times’, ‘Times New Roman’, ‘Arial’, ‘Courier’ or
similar Print should be font size 12.
Use 1.5 spacing.
Justify your work for neatness of appearance. Margins at both sides should be about 2.5 cm.
Long quotations should be in single spacing and indented at both sides.
Part 5: Appendices

References at the end of your work should be in single spacing, but you must leave a space between
each reference in your list.
There is no need to indent at the beginning of a new paragraph. Notice how the paragraphs above
are made distinctive by extra-line spacing.
The content in this guide has been adapted from work carried out by Nora O’Hara (SCBLM)
39
Appendix 2:
International Compliance Association Guidance
Note on Marking for Examiners and Students
1.
Marking Guide
This guidance note is intended for application to submitted written work and examinations. This paper
provides a broad description for each grade category and the factors to be considered and level of
attainment expected in each category. Some or all of these general standards and factors will normally be
taken into account when devising marking schemes for each piece of assessment.
Mark Range
Content
A range (Excellent)
70% and above
Work of excellent quality in
every respect. Focused and
comprehensive, with critical
depth and insight. Representing
a model answer at the top end of
the range.
Concise and comprehensive
identification of the issues
Excellent standard of critical
analysis using appropriate
conceptual frameworks and/or
applying relevant experience
and facts Comprehensive and
excellent use, evaluation and
synthesis of source material
Shows fresh thinking
and originality
Wholly relevant
B range (Good)
60% – 69%
Work demonstrating high
level of analytical and applied
competence on a broad range of
factors. Free of major errors.
Clear identification of
Clearly structured and
the issues
logically developed
High standard of critical
Clear, relevant and
analysis using appropriate
attainable objectives
conceptual frameworks and/or Relevant conclusions
applying relevant experience
supported by an appropriate
and facts
range and use of language
Good evaluation and synthesis
of source material
Shows some fresh thinking
and originality
Substantially relevant
C range (Pass)
Good attempt at identifying
50% – 59%
the issues
Work demonstrating clear ability
Uses appropriate
to acquire and apply knowledge
conceptual frameworks and/
in a coherent, if uncritical, fashion.
or relevant experience and
attempts analysis
Some evaluation and synthesis
of source material
Little originality
Adequately relevant
Structure
Well structured and
logically developed
Exceptionally clear, relevant
and attainable objectives
Clearly spelled out and
relevant conclusions
Supported by a good
range and appropriate use
of language
Reasonably clear structure
Reasonably clear, relevant and
attainable objectives
Attempts to reach a
clear conclusion
Rarely affected by
inappropriate use of language
41
D range (Marginal fail)
40% – 49%
Work demonstrating an
adequate attempt at acquiring
and applying knowledge.
Partial identification of
the issues
Adequate understanding and
use of appropriate conceptual
frameworks, experience and
facts; some errors
Some evidence of consulting
source material
No originality
Insufficient relevance
Links parts together, but lacks
a coherent structure
Clear, but limited, objectives
Does not always reach
a conclusion
Weakened by inappropriate or
inaccurate use of language
F range (Bad fail)
Inappropriate, or no,
Largely unstructured, showing
Below 40%
identification of the issues
little regard for the reader
Work demonstrating lack of ability Lacks understanding or use
Unclear, inappropriate, confused
on a broad range of factors.
of appropriate conceptual
or unattainable objectives
frameworks, experience and
Severely weakened by
facts and; many errors
inappropriate or inaccurate
No evidence of reading
use of language
and thinking
Largely irrelevant
Confused and confusing
Please note that the grade range refers to final assessment marks and is a guide only. It does not apply
to individual assignment marks.
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Appendix 3:
Referencing
1.
Suggested methods of reference
There are two main methods of referencing:
Footnotes/Endnotes (British Standard System): This is where you insert a number in the text next to the
quotation or borrowed idea and then type a note at the foot of the page or at the end of the essay to advise
the reader where you obtained the information.
Harvard Method: This uses brackets within the text of the essay to give the course specific information.
2.
How to reference
Different information is required dependent upon where the reference is taken from:
References taken from books require the following information:

Surname(s) of author(s), Initial(s).
Title, subtitle.
Edition (if 2nd addition or greater).
Place of publication, publisher.
Example: Graham, Bell and Elliott. Money Laundering. 2003. UK, Butterworths.
References taken from Journals/Articles require the following:

Surname(s) of author(s), Initial(s).
Year of publication.
Title of Journal. Volume/Part, pages.
For references taken from a website, quote the complete string so that if the reader typed it into explorer
it would take them to the exact page being referenced. If you are referring in general to an entire paper as
opposed to a specific line or paragraph then the string should be for the first/front page of the paper. For
example, if you were quoting rules in the FSA Handbook you would use the specific string to take the reader
to that rule if it were available on the web.
Direct quotations are usually enclosed in inverted commas and the number of the page from which the quotation
has been taken is always required. Long quotations should require double indenting or a smaller typeface.
Example: Graham, Bell and Elliott (2003) write:
“Thus the financial system has become the lifeblood of crime. This unpalatable realisation has led to a constellation
of new anti-crime initiatives undertaken at international and national levels over the past 25 years or so.” (p3)
Based on Information taken from MBS faculty of Arts website. Further information can be found on the Manchester
Business School Website at http://www.humanities.manchester.ac.uk/studyskills/assignments/reference/#main.
43
Appendix 4:
Examination Preparation
The following points, together with other exam preparation tips and techniques, are covered during the
Revision and Exam Preparation Session in the workshops. These should assist you in your preparations and
you might also find it useful to read through some of the Chief Examiners Reports on the ICT Website.
1.
Use of language
An examiner will always be impressed by clear, coherent and well-written examination answers. General
points that examiners look for are as follows:

coherency
logical overall structure of the examination answer
coherent sentence structure (including spelling, length)
unambiguous meaning
accuracy.
Attention should be paid to particular aspects of the language used, such as:

tenses

form of verbs

use of plural/singular

punctuation

appropriateness.
The appropriate form of language for an essay, assignment or problem is to strike a balance between not
being too formal (especially, do not use legal jargon) and not being too informal. Avoid expressing your own
views in terms such as ‘I think that’, but use expressions such as ‘a better view is that…’ or ‘it is suggested that…’.
2.
Examination answers – practices to avoid
The following is a list of common errors found in examination answers that should be avoided:

repeating the question
long introductions
irrelevance
absence of authority
too much authority
telling too much of the story of the cases you use for authority
jumping to a conclusion
no conclusion
inappropriate conclusion
illogical order
repeating information
incoherent paragraphs or sentences
ambiguity
inaccurate grammar – splitting infinitives; mixing singular and plural zz
inappropriate tone
use of slang or jargon.
45
3.
Examination Preparation Guidance
1.
2.
3.
4.
5.
6.
7.
46
Preparing properly for your examination is a crucial component in doing yourself justice and
succeeding in the examination.
If you have followed your study plan for the course you will have highlighted the examination date,
the date of the revision course and schedule for completing the work on each of the course modules.
The course, through its practical tasks, self-assessment questions (SAQs), and module outcomes,
encourages you to study the material on a weekly basis.
Work through any specimen examination papers prior to attending the revision course. Any points on
which you are unclear can be clarified through the tutor or at the revision course itself.
Do not stay up too late revising the night before the examination and avoid last minute ‘cramming’,
i.e. immediately prior to the exam.
Check with the revision course lecturer whether there have been any recent changes to the law or
practice of which you should be aware.
Read the examination protocols prior to the examination.
Part 5: Appendices
Appendix 5:
Examination Protocol
1.
Eligible examination aids
On the date of the examination, candidates may take with them into the examination room:

a dictionary
any notes, course materials and texts.
Candidates may not use a PC or handheld device.
2.
Identification required
Candidates must produce photo ID when registering at the examination venue.
3.
Admittance to examination room

4.
Leaving the examination room

5.
Other than to visit the toilet, once you leave the examination room, candidates will be ineligible to
return during that examination.
In fairness to others, candidates may not leave the examination room during the first 15 and last
30 minutes of the examination.
Behaviour in the examination room

6.
Candidates will not be allowed to enter the examination room until the invigilators give their
permission. At the start of the examination, the invigilator will require candidates to complete the
front sheet of the examination answer book on which the candidates must put their ID number,
industry sector and examination centre.
Candidates who are late may be admitted to the examination room at any time within the first 30
minutes of the examination, and thereafter no admittance will be allowed.
Switch off any digital watch alarm or mobile telephone.
During the period of the examination and the administration periods both before and after the
examination, candidates may not pass information nor talk to other candidates.
The invigilator shall make a written report of any unacceptable examination behaviour and ICA may
take this into account in deciding the success or otherwise of the candidate concerned.
The invigilator
The invigilator’s authority is final during the examination period. If candidates wish to complain about an
invigilator, they must do so to ICA in writing, whereupon ICA may investigate. Candidates will not be entitled
to a copy of ICA’s findings.
47
7.
Time calls
During the examination candidates may only turn the examination paper over and look at the questions
once the invigilator has signified the start of the examination.
Candidates are given 15 minutes reading time at the start of the examination. During this time candidates
may make notes on the examination paper but not on the examination answer book.
Once the examination has commenced, the invigilator will give the following time calls for the assistance
of examinees:

After 15 minutes – ‘you may begin writing’
‘1 hour to go’
‘10 minutes to go’
‘5 minutes to go’
‘Stop writing’.
The call to stop writing means no further writing may be carried out whatsoever. Thus, candidates must
ensure that all question numbers, delegates numbers etc, are completed before the call.
8.
Presentation of answers to essay/problem questions