Day 1
Those are the 3 main stages of a case review
What is Initial Due Diligence, Client Outreach, and Profile Completion?
It is an Entity Type that refers to a non-natural person Client who does not meet the requirement of other entity types.
What is Private Entity?
Managing Director, Member of the Executive Board, CEO
Can you name some examples of CSMs?
The first refers to money used by the client in the relationship with the bank and the second refers to the total money accumulated by the client
What's the difference between SoF and SoW?
They should always give sign-off at the end of the review (regardless of the type of the client).
When should KYC Ops and Business give their sign-off?
That refers to a representative of the bank who is responsible for a particular client and has the best knowledge about it.
Who is ACO?
You should select the one corresponding to higher risk.
What should you do if your client meets the requirements of more than one Entity type?
Principal industry, products or services offered, legal structure
What are the requirements of Nature of Business?
We use this tool for Negative News Screening when we have EDD clients
When do we use Lexis Nexis?
Those are risk factors which need to be escalated but not necessarily increase the client's risk to High.
What are Additional Risk Factors?
1st Line of Defense
Which line of defense corresponds to KYC OPS and Business?
Yes, if it does not have commercial purpose.
Do we use "Government & SoE" Entity type if our client is SOE?
The example is CSM who is also a shareholder with ownership marginally below the threshold level
What is an example of Significant Control indication?
Yes, if we know the Date of Incorporation (and depending on its value)
Can we prove that the client accumulated its wealth over a long period of time through its busienss activities?
They should be always reason for Escalation even if they are covered by compensating control.
When Bearer Shares in the client's ownership structure should be regarded as a reason for Escalation?
It is a relationship in which the party transacts with the bank on behalf of the Underlying Principal.
What is an "Agent" relationship?
Those are 3 types of parties that are usually UBOs for Trusts.
What are Settlor, Trustee, and Beneficiary?
Domination methodology
What is the name of the methodology in which, after the first level of ownership, each entity in the ownership structure can have a maximum or one direct owner (only the party that owns it in more than 50% directly)?
This is a process when the PEP left the office 12 or more months ago and does not have any other PEP role or did not return to the PEP role.
What is the reclassification PEP process?
Yes, it meets the SRP scenario, but only if the country in question is a prohibited SRC.
Does the client meet SRP6 scenario if it has revenues from a Special Risk Country?
It is one of the Risk Pillars which corresponds to intensity of the relationship between the client and the bank.
What is Channel Risk?
Some of its characteristics are narrowly-defined purpose and issuing of securities (for example, notes).
Can you name some characteristics of SPV?
Those are the steps of Plausibility check
When a part of ownership is only identified, you should:
1) Find proof of existence of your IBOs;
2) Request Plausibility assessment form the ACO;
3) Write a summary of the outcome of the Plausibility check;
What does those steps above refer to?
Reverse Screening
What can exempt us from the obligation of performing NLS on the Client and related parties?
Yes, they are in charge of accepting New High Risk Clients, but only in consultation with the Responsible AML Officer.
Is BSM (Business Senior Manager) in charge of accepting New High Risk clients?