Description

A focused course, tailored for you

Financial Crime Controls for Asset Leasing

Build KYC and AML controls that fit lease origination: from lessee due diligence through TRACFIN reporting and ACPR examination readiness.

The standard bank AML program handles deposit accounts and loans well. A leasing portfolio is different. The beneficial ownership layers in a corporate lessee, the asset valuation risk, the circular lease-back typology, the TRACFIN obligation for a leasing entity versus a banking entity: none of these map cleanly to the controls the parent bank built. The ACPR examiner sees the difference.

$199 one-time

Tailored to your situation. Access within 24 hours. 30-day money-back.

Includes a hand-built implementation playbook delivered alongside course access, generated for your specific situation.

Why this course

When the leasing AML program inherits controls designed for deposit and loan portfolios, the gaps become visible at examination time. The risk assessment for a lessee taking a five-year equipment lease looks structurally similar to a corporate loan on paper, but the money laundering typologies are distinct: inflated asset valuations submitted by a supplier with a beneficial ownership connection to the lessee, circular lease-back arrangements that move cash without triggering normal transaction alerts, special-purpose vehicle lessees designed to obscure the true controller of the equipment. The ACPR expects to see CDD documentation that reflects these specific typologies, not the generic banking template. TRACFIN declarations for leasing-specific suspicious activity require different narrative frameworks than those written for deposit accounts. Transaction monitoring rules built for account debits fire on the wrong signals for fixed lease rental payments. Each gap is individually manageable, but together they describe a control program that passes internal audit on the parent bank's framework and struggles under external examination on its own merits.

What you walk away with

Design a KYC workflow that maps to each stage of the lease lifecycle rather than the deposit account opening process.
Build transaction monitoring rules calibrated to lease payment patterns that detect structuring without flooding the queue with false positives.
Produce an ACPR-ready documentation trail for every lessee file, from initial CDD through the annual review cycle.
Write TRACFIN suspicious transaction declarations that address leasing-specific red flags with the narrative clarity the FIU expects.
Complete a gap analysis between the current control program and FATF guidance on asset-based financing to prioritise the improvement roadmap.

The 12 modules

Module 1. The Leasing AML Regulatory Map

How FATF Recommendations 10-16 apply specifically to asset-based financing rather than deposit-taking; the EU AMLD framework as it affects leasing subsidiaries of banking groups; what ACPR supervisory guidance on AML says about leasing operations versus the bank's core entity. Participants leave with a regulatory map showing which rules apply to which stages of the lease lifecycle.

Module 2. Customer Due Diligence at Lease Origination

CDD documentation standards for corporate lessees, including the beneficial ownership analysis when the lessee is a holding company or special-purpose vehicle. How to structure the risk-based approach during application processing so the CDD file is examination-ready from day one. Templates for the documentation trail an ACPR examiner expects to find in an origination file.

Module 3. Asset-Based Money Laundering Typologies

The FATF guidance on asset-based money laundering applied to equipment and vehicle leasing: inflated valuations, circular lease-back arrangements, and special-purpose lessees designed to obscure beneficial ownership. How to identify these patterns at origination and during portfolio review. Case typologies drawn from FATF and Egmont Group publications on asset-based financial crime.

Module 4. KYC Workflow for the Lease Lifecycle

Mapping KYC obligations to each stage of a lease: origination, drawdown, annual review, material modification, and end-of-term disposal. How to design handoffs between the sales, credit, and compliance functions so nothing falls through. Which stages require a full CDD refresh and which require only a targeted file update based on the risk-based approach.

Module 5. Sanctions Screening in Asset Leasing

How to screen corporate lessees, beneficial owners, equipment suppliers, and guarantors against OFAC, EU, UN, and French SDFM lists. The specific challenge of dual-use equipment categories and leasing to customers with cross-border operations. How to document screening outcomes and manage the escalation path for potential matches with the evidence standard ACPR expects.

Module 6. Transaction Monitoring for Lease Cash Flows

Designing monitoring scenarios specific to lease payment patterns: fixed rental payments, variable lease income, early termination settlements, and buyout amounts. How to calibrate alert thresholds for different portfolio segments without generating unmanageable false positive volumes. How to distinguish normal lease payment variability from structuring or other unusual payment behaviour.

Module 7. TRACFIN Declarations for Leasing Entities

When and how to file a suspicious transaction declaration with TRACFIN as a leasing entity. How leasing-specific red flags, including unusual lessee behaviour, unexpected asset use, and suspicious end-of-term disposal patterns, translate into declaration narratives. The documentation required to support a declaration and the internal approval workflow that satisfies both ACPR expectations and TRACFIN standards.

Module 8. Enhanced Due Diligence for High-Risk Lessees

Identifying which lessees require EDD: PEP-linked entities, companies in high-risk jurisdictions, sectors with elevated asset-based money laundering exposure including extractives, real estate, and defence. How to conduct EDD efficiently without blocking the origination process. What documentation the EDD file must contain to satisfy ACPR examination requirements and internal audit standards.

Module 9. Internal Controls and Three Lines of Defence

Building first-line controls into the lease origination and portfolio management workflow. Designing second-line oversight metrics that give the financial security officer real-time visibility into the control environment without requiring manual sampling. What internal audit should be testing in a leasing AML program and how to respond to internal findings before they escalate to regulatory attention.

Module 10. ACPR Examination Readiness for Leasing

How ACPR structures AML examinations of leasing subsidiaries, and what distinguishes these from examinations of the parent banking entity. The most common examination findings in the leasing sector and how to address them before the examination begins. Building a documentation file that answers the standard ACPR information request and preparing the team to respond to examiner questions on specific lessee files.

Module 11. Cross-Border Leasing and Regulatory Conflicts

When a French leasing entity operates across EU borders, different national AML transposition rules create conflicting compliance obligations. How to build controls that satisfy both ACPR and a host-country regulator simultaneously. The EU passporting framework as it applies to leasing operations and the specific conflict points between French AMLD implementation and requirements in other major EU jurisdictions.

Module 12. The AML Improvement Roadmap

A structured gap analysis between the current leasing AML program and the regulatory expectations mapped across modules 1 through 11. How to prioritise control improvements by regulatory risk level and implementation effort. How to present the improvement program to the risk committee and board with a credible delivery timeline that demonstrates the program is moving toward examination readiness.

How this addresses your situation

Specific modules that map to what you said you are dealing with.

Pre-ACPR examination preparation with a leasing portfolio, uncertain which documentation the examiners will focus on: start with modules 2, 9, and 10.

Designing or rebuilding KYC controls for a new lease origination channel or product line: work through modules 2, 4, and 8 in sequence.

Responding to an internal audit finding about AML control gaps in the leasing portfolio: modules 3, 6, and 9 cover the most common gap categories.

Filing TRACFIN declarations for leasing-specific suspicious activity for the first time, or improving existing declaration quality: modules 7 and 3 together.

What you get with this course

12 text-based modules covering the full lease AML control lifecycle from origination through end-of-term
Downloadable KYC workflow templates mapped to each stage of the lease lifecycle
ACPR examination preparation checklist and documentation file template
TRACFIN declaration narrative guide for leasing-specific red flags
Gap analysis template for benchmarking the current program against FATF guidance and ACPR supervisory expectations
The hand-built implementation playbook covering your specific portfolio risk profile, delivered alongside course access

What you will have in hand by Day 1, Week 1, Month 1

Course access provisioned within 24 hours of purchase.

The hand-built implementation playbook delivered alongside course access, covering your specific leasing portfolio risk segments.

All 12 modules and downloadable templates available immediately on access, with no time limit on completion.

Before and after

Before

The leasing AML program follows the parent bank's standard framework and passes internal audit. But the documentation trail does not map to what an ACPR examiner expects for a leasing-specific risk profile, and examination findings arrive as surprises that require reactive remediation.

After

The control program is designed around lease lifecycle stages, with CDD documentation, transaction monitoring rules, and TRACFIN procedures that an ACPR examiner recognises as fit-for-purpose. Examination preparation takes days rather than weeks, and findings are anticipated rather than reactive.

What happens if you do not address this

Continued misalignment between leasing AML controls and ACPR supervisory expectations increases regulatory risk at the next examination. Asset-based money laundering typologies the current program does not detect expose the portfolio to financial crime risk and potential supervisory action, including formal findings that require the parent bank to remediate the gap under ACPR oversight.

Who it is for

Senior compliance and financial security professionals who own the AML program at an equipment or vehicle leasing subsidiary or division of a banking group. They understand the parent bank's AML framework and have implemented it in the leasing entity, but they find that the controls satisfying internal audit do not fully satisfy the ACPR examiner's expectations for a leasing-specific risk profile. They are preparing for or recovering from an examination, building out the program following a recent appointment, or designing controls for a new leasing product line.

Who this is NOT for. Generalist banking AML analysts with no leasing portfolio exposure; compliance professionals working only in retail banking or trade finance who want an introduction to AML fundamentals; anyone looking for ACAMS or ICA certification exam preparation rather than operational control design.

How it arrives

Text-based course in the Art of Service learning environment, plus downloadable templates and worked examples for every module, plus the hand-built implementation playbook delivered alongside course access.

Time investment. Designed for working compliance professionals. Each module takes 30 to 45 minutes. The full course runs in 6 to 8 hours across a standard working week.

Why $199 is the right number

General AML certification courses cover the full regulatory landscape for banking broadly, not asset leasing specifically. Internal training covers the parent bank's framework, which does not address the leasing-specific typologies that ACPR examiners focus on. This course is built for the gap between those two, where the operational control design lives.

FAQ

Does this cover French-specific ACPR requirements?

Yes. The TRACFIN declaration process, ACPR examination preparation, and the specific supervisory expectations for leasing subsidiaries are covered in modules 7, 9, and 10. EU AMLD requirements that apply across EU operations are covered in modules 1 and 11.

How is the implementation playbook tailored to my situation?

After purchase, I review your role and leasing portfolio profile and hand-build a playbook that maps the course control frameworks to your specific operating environment, including your key risk segments, your regulatory reporting lines, and any known examination findings you are working to address.

Is this relevant for leasing subsidiaries operating outside France?

Yes. The control design principles apply across EU leasing operations. Module 11 covers cross-border regulatory conflicts specifically, including how to reconcile ACPR requirements with other EU national competent authorities in jurisdictions where the leasing entity operates.

30-day money-back guarantee. If after a week of working through the materials this is not what you needed, reply to the receipt email and a full refund is processed. No questions, no forms.

Within 24 hours your account in the learning environment is provisioned and the tailored implementation playbook is delivered alongside it.