Enhanced Due Diligence for Employee Reviews | CAMS Exam

Employee Action Warranting Enhanced Due Diligence

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Question

An anti-money laundering officer is conducting employee reviews.

Which employee action warrants enhanced due diligence?

Answers

Explanations

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A. B. C. D.

C

The correct answer is A - The teller reviews customer profiles and makes notations of personal information to reportedly become familiar with bank customers.

Enhanced due diligence (EDD) is a higher level of scrutiny and investigation that financial institutions are required to apply to customers that are deemed to present a higher risk of money laundering or terrorist financing. EDD measures are typically applied to customers that present higher risks due to factors such as their geographic location, type of business, or suspicious behavior.

In the given scenario, the teller's behavior of reviewing customer profiles and making notations of personal information could be considered suspicious and warrant EDD. The teller's actions could be indicative of attempting to circumvent customer identification requirements or trying to gain an undue familiarity with customers to facilitate illicit activity. This behavior could indicate potential money laundering or other illicit activities, and the institution should undertake additional due diligence to ensure that it is not inadvertently facilitating such activities.

Option B, the private banker taking long vacations, is not a behavior that would typically warrant EDD. Although this behavior may have caused work-related stress or delays, it is not indicative of potential money laundering or other illicit activity.

Option C, the branch manager reviewing the daily hold report and releasing holds on non-cash items once the bank receives credit from the paying bank, is a standard banking practice that does not warrant EDD.

Option D, the bank chief executive officer living in a lavish home and requesting board approval for a country club membership payment, may raise concerns about the source of the executive's wealth or potential conflicts of interest, but it is not indicative of money laundering or other illicit activities and does not warrant EDD. However, it may warrant further investigation or scrutiny to ensure that the executive's behavior does not violate ethical or legal standards.