During the regular periodic review of a high-risk client, a KYC analyst performs EDD checks and detects the presence of a politically exposed person. The KYC analyst should escalate this issue to the:
Answer : B
When a politically exposed person (PEP) is identified during enhanced due diligence, FATF requires that senior management approve the decision to continue or terminate the relationship due to the elevated financial crime risk.
During the onboarding process of a new customer, it is noted that the customer is a politically exposed person opening a private banking account and has a foreign passport. Which statement best describes the industry best practice for the institution?
Answer : A
Which is an example of an EDD measure?
Answer : C
Obtaining and verifying the customer's source of wealth is a key Enhanced Due Diligence (EDD) measure, especially for high-risk customers such as PEPs, as it helps assess the legitimacy of their funds.
A legal entity applies to open an account in a financial institution. The owners of the entity are 20 individuals with equal shareholding. Who should be identified as the Ultimate Beneficial Owner (UBO), per Financial Action Task Force (FATF) guidelines?
Answer : D
FATF guidelines require identifying UBOs as individuals owning more than 25% or, if no one meets that threshold, those who exercise control through other means. In this case, no shareholder owns more than 25%, so the UBO is identified based on control, typically the person(s) in senior management.
A KYC analyst suspects a transaction is related to a sanctioned individual. How should the analyst respond?
Answer : D
Any suspicion of a link to a sanctioned individual must be reported immediately through the institution's defined sanctions compliance procedures to ensure legal and regulatory obligations are met without tipping off the customer.
A compliance officer in an international bank is reviewing new customer onboarding files. The relationship manager provides a whole set of customer documents, in addition to information from open source research. What information should be used by the compliance officer as secondary documentation to verify the primary documentation?
Answer : A
Secondary documentation for verification purposes should be recent, reliable, and issued by a trusted source. Utility bills, phone bills, or bank statements issued within the last three months are commonly accepted to confirm address and identity details provided in primary documentation.
A KYC analyst notices frequent use of letters of credit as a method of trade finance. It further appears that trades covered by letters of credit are not consistent with the customer's usual business. What should be the next action taken by the KYC analyst?
Answer : B
Unusual trade finance activity, such as letters of credit inconsistent with the customer's normal business, is a potential red flag for trade-based money laundering. The appropriate step is to make an internal referral for review and possible filing of a suspicious transaction report (STR).