CAMS · Question #172
The Board of Directors for a small private bank has asked the management to no longer apply the identity requirements for high net worth individuals to protect their privacy. Which of the following Fi
The correct answer is C. Financial institutions should maintain all necessary suspicious transaction report records on. When a board directs staff to waive identity requirements for high-net-worth clients, the AML specialist must recognize that record-keeping obligations under FATF Recommendation 11 are the foundational control that enables all other AML obligations to function.
Question
The Board of Directors for a small private bank has asked the management to no longer apply the identity requirements for high net worth individuals to protect their privacy. Which of the following Financial Action Task =once 40 Recommendations should cause an anti-money laundering specialist the most concern?
Options
- AFinancial institutions should not warn their customers when information relating to them is being
- BFinancial institutions should not keep anonymous accounts.
- CFinancial institutions should maintain all necessary suspicious transaction report records on
- DIf financial institutions suspect that funds stem from criminal activity, they should be required to
How the community answered
(40 responses)- A8% (3)
- B5% (2)
- C73% (29)
- D15% (6)
Why each option
When a board directs staff to waive identity requirements for high-net-worth clients, the AML specialist must recognize that record-keeping obligations under FATF Recommendation 11 are the foundational control that enables all other AML obligations to function.
The prohibition on tipping off customers is an important FATF requirement but is not directly triggered by the failure to collect identity documents from HNW clients.
The prohibition on anonymous accounts is relevant but is itself a consequence of applying proper identity requirements - the record-keeping requirement in Recommendation 11 is the specific rule most directly violated when identity data is not collected.
FATF Recommendation 11 requires financial institutions to maintain complete records of customer due diligence information and transactions for at least five years. If identity requirements are waived for HNW clients, the institution cannot compile the accurate, complete records required to support any suspicious transaction report, making all downstream reporting obligations impossible to fulfill and placing the institution in direct violation of this foundational record-keeping requirement.
The obligation to report suspected criminal activity is critical but cannot be effectively carried out without the underlying identity records - the record-keeping deficiency addressed in C is the root cause that makes proper STR filing in D impossible.
Concept tested: FATF Recommendation 11 record-keeping requirements
Source: https://www.fatf-gafi.org/en/publications/Fatfrecommendations/The-forty-recommendations.html
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