Escalation & Consutation
Approaching Responsible AML Officer (AFC) when it is unclear whether an identified issue is a material risk factor or not.
What is AFC Consultation?
They are given by CLM and business at the end of the review.
When are the Sign-offs given?
It is divided into Prohibited and Restricted countries.
What are the two categories which the Special Risk Countries list is split into?
Parties who are not the clients (nor CSMs, UBOs or IBOs), but who are involved in the transactions of the bank and may act on behalf of the client.
What are Other Relevant Parties?
At the end of the review, if there is no suspicion that the bank's account can be currently/soon utilised for illegal purposes.
When standard AFC Escalation takes place?
Those parties' sign-offs are always required (for RR and EDR).
When is Business Approval (ACO's) and CLM Sign-off required?
Examples are Iran and North Korea.
Can you name two examples of Prohibited Special Risk Countries?
It is a natural or non-natural person who introduces potential clients (or business) to the bank or fulfil Due Diligence Requirements.
What is an Intermediary?
Always when the client's risk increased to high or when there are new special/additional risk factors identified during the review.
When is AFC Escalation required?
It is provided in consultation with Responsible AML Officer when the client's risk moves from low/medium to high (or falls from high) or when wavier is used during the review (and in various other scenarios).
When is BSM Approval required?
It falls within the scenario of SRP6 (Special Risk Party 6).
Which SRP scenario applies for a client which is holding assets/receiving revenues from a Prohibited Special Risk Country?
Brokers or parties performing due diligence on behalf of the DB.
What are the examples of Intermediaries?
CLM is in charge of coordinating it.
Who is in charge of coordinating the Escalation/Consultation process?
Temporary or Permanent.
What are the types of waivers?
When the client's revenues are above 5% on aggregate basis (from any SRCs in total) or are above 2% of one prohibited SRC.
When does the Sanctions Risk Acceptance Procedure need to be initiated?
These relationships present increased corruption risk and reliance cannot be placed on information received from such parties.
Why must Business Development Consultants as Intermediaries be escalated to AFC?
It is applied when the only risk factors identified during the review are the ones which were already previously escalated. AFC just approves the review without checking it.
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?
When the broker is acting on behalf of our client and the bank does not have a relationship with the broker.
When does Intermediary Broker require only Name List Screening?