Escalation & Consutation
Approaching Responsible AML Officer (AFC) when it is unclear whether an identified issue represents a risk factor that requires escalation.
What is AFC Consultation?
They are given by KYC Ops and Accountable Client Owner (ACO) at the end of the review.
Prohibited and Restricted countries.
What are the two categories of Special Risk Countries?
5% or more
(Topic: Determining entity type)
What is the threshold for treating a client active in the gambling industry as a "Gambling" entity type?
At the end of the review, if there is no suspicion that the bank's account are currently/can soon be utilised for illegal purposes.
When does standard AFC Escalation take place?
Approval and sign-offs from these parties are required always (for RR and EDR).
When is KYC Ops' and ACO's Approval and Sign-off required?
Examples are Iran and North Korea.
What are two examples of Prohibited Special Risk Countries?
Olga Faszcza
Who conducted training on Day 1 and Day 4 of the Project Induction?
Always when the client's risk increased to high or when there are new additional risk factors identified during the review.
When is AFC Escalation required?
When the client's risk rating moves to high, or from high to medium/low, in case of new cross-border correspondent relationship, when a CSM is a PEP, and more...
When is Business Senior Manager (BSM) Approval required?
It falls within the scenario of SRP6 (Special Risk Party 6).
Which SRP scenario applies for a client who receives revenues from a Prohibited Special Risk Country?
Activities that have generated the total net worth of a person
What is Source of Wealth?
UBO identified as a PEP
What is an example of a Per Se High Risk factor?
Temporary or Permanent.
What are the two types of waivers?
When the client's revenues are above 5% on aggregate basis or are above 2% of one prohibited SRC.
When does the Sanctions Risk Acceptance Procedure need to be initiated?
Nexis Diligence screening
What additional screening must be conducted for High Risk clients?
It is applied when the only risk factors identified during the review are the ones which have already been escalated in the previous review. AFC just approves the review without conducting a full review.
What is Technical Release?
90 days.
What is the maximum validity period for a temporary waiver?
It is valid for 12 months and must be completed and signed by the Business Outreach Support, ACO, Business Sponsor or the Client.
What are the requirements of a Sanctions Questionnaire?
A check undertaken in order to determine whether the client's ownership and control structure is credible and in line with expectations.
What is Plausibility check?