CAMS · Question #47
Which two factors should increase the risk of a correspondent bank customer and require additional due diligence according to the Wolfsberg Anti-Money Laundering Principles for Correspondent…
The correct answer is C. The customer is located in a Financial Action Task Force member country and provides services D. The customer is located in a non-Financial Action Task Force member country and services. The Wolfsberg AML Principles for Correspondent Banking identify specific jurisdictional and service-related factors that elevate customer risk and trigger additional due diligence obligations.
Question
Which two factors should increase the risk of a correspondent bank customer and require additional due diligence according to the Wolfsberg Anti-Money Laundering Principles for Correspondent Banking? (Choose two.)
Options
- AThe customer is located in a Financial Action Task Force member country and provides services
- BThe customer is located in a Financial Action Task Force member country and the bank's head of
- CThe customer is located in a Financial Action Task Force member country and provides services
- DThe customer is located in a non-Financial Action Task Force member country and services
How the community answered
(50 responses)- A10% (5)
- B20% (10)
- C70% (35)
Why each option
The Wolfsberg AML Principles for Correspondent Banking identify specific jurisdictional and service-related factors that elevate customer risk and trigger additional due diligence obligations.
Location in a FATF member country and provision of routine services does not, by itself, constitute a risk-elevating factor under the Wolfsberg Principles without additional indicators such as high-risk customer types or opaque ownership.
The involvement of a bank's senior compliance officer is a governance indicator rather than a risk-increasing factor, and it does not appear in the Wolfsberg Principles as a trigger for additional due diligence.
Under the Wolfsberg Principles, a correspondent customer located in a FATF member country that provides services such as nested accounts or payable-through accounts to higher-risk sub-customers presents elevated exposure, because the correspondent bank inherits indirect risk from those downstream clients. Even FATF membership does not neutralize risk when the customer's service model extends access to unvetted third parties.
Customers domiciled in non-FATF member countries represent a structurally higher risk because those jurisdictions lack the standardized AML/CFT oversight, mutual evaluation processes, and enforcement frameworks that FATF membership requires. The Wolfsberg Principles explicitly list non-FATF jurisdiction as a factor requiring enhanced due diligence.
Concept tested: Wolfsberg Principles correspondent banking elevated risk factors
Source: https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/Wolfsberg_Correspondent_Banking_Principles_2014.pdf
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