Lecture 10. Additional measures for specific customers, entities and professions

Key terms

· politically exposed persons (PEPs)

· foreign PEPs

· domestic PEPs

· home country operations

· foreign operations

· applicable threshold

· reporting requirements

Key questions

· Give the definition and classification of PEPs.

· List prominent public functions that a PEP can be entrusted with.

· Can a middle ranking individual be classified as a PEP?

· Which measures in addition to normal CDD procedure should a financial institution implement when it has determined that a customer is a foreign PEP?

· What should a bank do in the course of determining that a client is a domestic PEP?

· List the measures applicable to a domestic PEP in case of a higher risk.

· Up to which extend should the financial institution apply AML/CFT requirements of the home country to foreign operations?

· What should the financial institution do if the AML/CFT legislature of the host country does not permit full implementation of the AML/CFT requirements of the home country?

· The AML/CFT legislature of a host country does not permit full implementation of the AML/CFT requirements of the home country. What can home country supervisors request the financial group to do with its foreign operations in the country?

· Which recommendations related to CDD and RBA are applicable to DNFBP?

· Define the circumstances under which CDD measures are applicable to casinos.

· Under which circumstances is a dealer in precious metals required to perform CDD and to file an STR?

· A lawyer and a real estate agent are involved in a transaction for their client and are required to perform CDD. What is this transaction?

· Which transactions for their clients do independent accountants need to perform in order to fall under AML/CFT record keeping requirements?

· Whom should real estate agents identify in transactions regarding buying and selling real estate?

· To what must a casino be able to link the CDD information?

· List the circumstances when a lawyer is subject to professional secrecy and is exempt from sending an STR.

· What is unique about the way a notary can file an STR?

· To which types of independent accountants should the reporting activities be extended?

· An independent legal professional finds out that his customer is trying to engage in illegal activity. Name a specific feature of tipping-off by this professional.

Date: 2015-01-29; view: 855