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 intermediaries to align it with the Wolfsberg Anti-Money Laundering Principles for Private
Banking? (Choose two.)
Click on the arrows to vote for the correct answer
A. B. C. D.BD
https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/faqs/20.%20Wolfsberg-FAQs-on-Intermediaries-May-2012.pdf(2)
The correct answers are B and C.
The Wolfsberg Anti-Money Laundering Principles for Private Banking are a set of guidelines developed by a group of international banks to provide guidance on best practices for anti-money laundering (AML) and counter-terrorism financing (CTF) compliance in the private banking sector.
The two aspects that should be included in the policy in respect of intermediaries to align it with the Wolfsberg Anti-Money Laundering Principles for Private Banking are:
B. Where an intermediary introduces clients to the bank, the bank must obtain the same type of information with respect to an introduced client that would otherwise be obtained by the bank, absent the involvement of the intermediary.
This means that the bank should perform due diligence on the intermediary's clients as if the bank had a direct relationship with them. The bank should obtain the same type of information that would be obtained if the client had approached the bank directly. This includes information about the client's identity, source of funds, and beneficial ownership. This is important because intermediaries can be used to mask the true identity of clients and the source of their funds.
C. Where an intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but that intermediary does not conduct the same level of due diligence as the bank, it is necessary for the bank to undertake due diligence on the intermediary's clients.
This means that the bank should perform due diligence on the intermediary's clients if the intermediary manages assets on behalf of a number of clients and is the account holder with the bank, but does not conduct the same level of due diligence as the bank. This is important because intermediaries can be used to provide access to the banking system for high-risk clients who would not otherwise have access. The bank should ensure that it has sufficient information about the intermediary's clients to assess the risks associated with them.
Answers A and D are incorrect because:
A. When an intermediary introduces clients to the bank, it is not necessary for the bank to perform due diligence on the intermediary's clients.
This answer is incorrect because, as mentioned earlier, the bank should perform due diligence on the intermediary's clients as if the bank had a direct relationship with them.
D. Where an intermediary manages assets on behalf of a number of clients and arranges for the opening of accounts for its clients with the bank, and that intermediary is a financial institution subject to similar regulations, it is necessary for the bank to perform due diligence on the intermediary's clients.
This answer is incorrect because it only applies if the intermediary is a financial institution subject to similar regulations. If the intermediary is not a financial institution subject to similar regulations, the bank should still perform due diligence on the intermediary's clients.