The compliance officer for a private bank has been tasked with writing a policy on how the bank will deal with intermediaries. Which two aspects should be included in the policy in respect of…

Question

Options

• AWhen an intermediary introduces clients to the bank, it is not necessary for the bank to perform
• BWhere an intermediary introduces clients to the bank, the bank must obtain the same type of
• CWhere an intermediary manages assets on behalf of a number of clients and is the account
• DWhere an intermediary manages assets on behalf of a number of clients and arranges for the

• A
  6% (3)
• B
  81% (38)
• D
  13% (6)

Explanation

According to the Wolfsberg Anti-Money Laundering Principles for Private Banking (2012), the bank should have a clear policy on how to deal with intermediaries, such as lawyers, accountants, trust and company service providers, or other financial institutions, that introduce or manage clients on behalf of the bank. The policy should reflect the following aspects1: The bank should perform due diligence on the intermediary itself, including its ownership, reputation, regulatory status, and AML policies and procedures. The bank should obtain the identity and beneficial ownership information of the clients introduced or managed by the intermediary, and verify them using reliable and independent sources, unless there are legal or regulatory impediments to do so. The bank should assess the level of due diligence performed by the intermediary on its clients, and determine whether it is equivalent or comparable to the bank's own standards. If not, the bank should perform additional due diligence on the intermediary's clients, or decline to accept

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