The compliance officer for a private bank has been tasked with reviewing the procedure for authorized signatories on customer accounts to ensure it is in line with relevant Wolfsberg Anti-Money Laundering Principles for Private Banking.
Which three statements from the procedure are in line with Wolfsberg? (Choose three.)
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A. B. C. D. E.CDE
https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/faqs/20.%20Wolfsberg-FAQs-on-Intermediaries-May-2012.pdfThe Wolfsberg Group is a leading association of thirteen global banks and other financial institutions that provides guidance and best practices to combat financial crime. Their Anti-Money Laundering Principles for Private Banking provides a set of guidelines to help financial institutions prevent money laundering and terrorist financing in their private banking operations. In this context, the compliance officer for a private bank is reviewing the procedure for authorized signatories on customer accounts to ensure that it aligns with these principles.
Based on the information provided, three statements that are in line with the Wolfsberg Anti-Money Laundering Principles for Private Banking are:
A. Where the Authorized Signatory is not a lawyer or accountant, due diligence as to the source of funds and wealth of the Authorized Signatory should be undertaken.
This statement aligns with the Wolfsberg Principle 3, which states that financial institutions should conduct enhanced due diligence on customers that are classified as high risk, including those with a higher potential for money laundering or terrorist financing. This would include authorized signatories who are not lawyers or accountants, where the bank would need to understand the source of their wealth and the funds used to establish the relationship with the bank.
B. The responsible private banker must establish the identity of a holder of general powers over an account (e.g. a signatory for the account) and, as appropriate, verify that identity.
This statement aligns with the Wolfsberg Principle 2, which requires financial institutions to identify and verify the identity of their customers, including authorized signatories. The bank must establish the identity of the holder of general powers over the account, such as a signatory, and verify that identity using reliable and independent sources.
D. The responsible private banker must obtain the necessary documentation establishing the authorized signer's authority to act on behalf of the account holder or beneficial owner (e.g. a Power of Attorney).
This statement aligns with the Wolfsberg Principle 5, which requires financial institutions to obtain and verify the necessary documentation for their customers, including authorized signatories. This documentation should establish the authorized signer's authority to act on behalf of the account holder or beneficial owner, such as a Power of Attorney, and should be obtained before the bank establishes a relationship with the customer.
Therefore, statements A, B, and D are in line with Wolfsberg Anti-Money Laundering Principles for Private Banking. Statements C and E do not align with the principles as they suggest reducing due diligence on account holders and authorized signers, which goes against the guidance provided by Wolfsberg.