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?
Examples are UBOs, IBOs, CSMs.
What are examples of Other Relevant Parties?
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 standard AFC Escalation takes 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?
It is a natural or non-natural person who introduces potential business or clients to the bank.
What is an Intermediary?
Ferlyn Gorembalem and Charlotte Plazos
Who conducted training on Day 1 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 holds assets in /receives revenues from a Prohibited Special Risk Country?
What is not incorporated into the risk rating of Intermediaries?
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?
Due to the fact that relationships with these parties acting as 3rd parties present increased ML/TF risks (e.g. Bribery and Corruption risk).
Why do Business Development Consultants acting as Third Parties need to be escalated to the Responsible AML Officer?
Lexis 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?
Because intermediaries do not hold DB products.
Why isn't the product risk factor incorporated in the risk rating of intermediaries?
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?