You are a member of the AML team of a regulated firm in a jurisdiction of your choice. You
are currently conducting a file review of clients.
a) Analyse the following scenarios from the perspective of AML/CFT risk, in particular
with regard to customer due diligence issues.
(b) Evaluate the issues faced by those conducting customer due diligence on a client in
respect of determining ‘source of wealth’ and ‘source of funds’.
i) Hubert, an existing high-net-worth client of the firm, has been requested to
produce updated information relating to his business activities. Hubert
responds that he is too busy to deal with the queries, has been a customer of
the firm for over 10 years and is well known to the firm’s managing director and
as such should not be subject to such requests. He insists that if the firm does
not take a more reasonable approach he will move his business elsewhere.
ii) Alexis is a former judge who worked in Zimbabwe until two years ago. Since
moving his accounts and associated substantial wealth to the bank in your
jurisdiction, there has been a further significant flow of funds to his accounts
from South Africa and surrounding regions. There is a scarcity of due diligence
information on his files as he indicated that much of the information is in
Zimbabwe, which he was required to leave in a hurry.
iii) The account opening division of the firm has been requested to establish a
business relationship with a newly incorporated client, BCD Ltd. In attempting
to determine ultimate beneficial ownership of BCD Ltd, the research team have
met with a complex structure of offshore corporate ownership. The team have
been unsuccessful in determining the true owners because of complex
subsidiary holdings often incorporated via offshore corporate service providers
and share ownership held in trust structures.
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