All questions can be answered in relation to a jurisdiction with which you are familiar.

Question 1

You have recently been appointed as an assistant to the Money Laundering Reporting Officer (MLRO) at World Business (WB) a firm regulated in a jurisdiction and sector of your choice. The MLRO was also recently appointed to the role and prior to him joining, the role had been vacant for six months as a result of the previous MLRO having resigned. No acting MLRO was appointed following that departure, but the money laundering prevention team was asked to collectively share the responsibilities until a new MLRO was appointed. This unfortunately took far longer than anticipated.

One of the new MLRO’s first actions was to commission a complete review of anti money laundering (AML) systems and controls. This identified a number of points of concern, including the following:

•               • a backlog of Suspicious Activity Reports (SARs) that have been reported to the team but not yet actioned or investigated;

•               • incomplete client due diligence (CDD) records on a number of new accounts.

The new MLRO intends to raise his concerns about these findings with the board of WB. However before doing so he asks that you assist him in addressing these concerns by carrying out the following actions.

•               a) Outline the potential implications for WB of the findings referred to in the above scenario and set out the steps that you recommend to help mitigate any potential consequences. Support your views with appropriate examples.

(20 marks)

•               b) Produce a paper that outlines plans for an AML systems and controls refresher training course for the money laundering prevention team, with specific emphasis on the firm’s processes and the role and responsibilities of the MLRO and his/her team. The paper should indicate the content of the training to be carried out, explaining the purpose of each element of content and how this would be delivered to ensure it was effective in achieving its intended aims.

(30 marks)

Total 50 marks UK Advanced Certificate in Compliance – Assignment Two – 08 April 2019

3 ICAA264

Question 2

You are a junior member of staff working in the compliance department of a firm regulated in a jurisdiction and sector of your choice.

Working with your line manager and a number of your compliance colleagues, you are currently involved in a project to develop material on a range of compliance and risk topics. This material will be incorporated into the continuous professional development database for the firm, which is currently being updated. This material provides guidance on various subjects which can then be accessed to give information on a variety of development activities for staff at all levels across the firm.

Each member of the project team has been assigned a particular subject on which to focus, linked to the overall objectives of the material to be produced. Your assigned subject is financial crime prevention (excluding money laundering), and you have been asked to prepare a short guidance paper about this. The guidance paper should explain:

•               • what the main financial crime risks faced by your chosen company are, showing why these are the main risks

•               • how such risks are monitored, why and by whom.

Produce this guidance paper, highlighting the key points that should be emphasised to ensure understanding of this subject and explaining why it is important that all staff within the firm should understand this. Your paper should support the purpose of the material being produced and the needs of the intended audience, providing appropriate examples in doing so.

Total 50 marks

Total 100 marks