CAMS · Question #585
A senior government official is trying to open an account in a financial institution (FI) that operates in a different country from where the official is domiciled. The official is using an asset…
The correct answer is C. Reasonably establish if the source of wealth and funds of the official is legitimate. D. Perform due diligence procedures on the managing intermediary. E. Determine whether the intermediary representative is acting on the officer's behalf. Reasonably establish if the source of wealth and funds of the official is legitimate. This is to ensure that the FI is not facilitating the laundering of proceeds of corruption, bribery, or other illicit activities by the official, who is considered a politically exposed person…
Question
A senior government official is trying to open an account in a financial institution (FI) that operates in a different country from where the official is domiciled. The official is using an asset manager intermediary to represent them. According to the Wolfsberg Group, which next steps should the FI take regarding the opening of the account? (Select Three.)
Options
- AReport to authorities that a possible suspicious activity is being undertaken by a politically
- BScreen for applicable sanctions only for the official in the name of the person for whom the
- CReasonably establish if the source of wealth and funds of the official is legitimate.
- DPerform due diligence procedures on the managing intermediary.
- EDetermine whether the intermediary representative is acting on the officer's behalf.
- FEnsure the official's client file is updated so that the information is maintained in a consistent and
How the community answered
(23 responses)- A4% (1)
- B4% (1)
- C83% (19)
- F9% (2)
Explanation
Reasonably establish if the source of wealth and funds of the official is legitimate. This is to ensure that the FI is not facilitating the laundering of proceeds of corruption, bribery, or other illicit activities by the official, who is considered a politically exposed person (PEP) and poses a higher risk of financial crime. The FI should obtain information and documentation on the origin and ownership of the funds, the official's income and assets, and the purpose and expected activity of the account. Perform due diligence procedures on the managing intermediary. This is to verify the identity, reputation, and regulatory status of the intermediary, who acts as a third party on behalf of the official. The FI should also assess the intermediary's own AML/CFT policies and controls, and the nature and extent of the relationship between the intermediary and the official. Determine whether the intermediary representative is acting on the officer's behalf. This is to establish the beneficial ownership and control of the account, and to avoid any potential conflicts of interest or undue influence by the intermediary. The FI should obtain a written confirmation from the intermediary that they are authorized to act on behalf of the official, and that they will disclose any changes in the beneficial ownership or control of the account.
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