FRM Part II · FRM Exam Part II · Sound Management of Risks Related to Money Laundering and Financing of Terrorism
A bank in Country A offers correspondent services to a respondent bank in a higher-risk jurisdiction. Under the Basel Committee guidance on sound management of ML/FT risks, which step should the bank take BEFORE establishing the correspondent relationship?
The bank should gather sufficient information on the respondent's business, reputation, supervision and AML/CFT controls and obtain senior management approval before opening the relationship. Deferring due diligence, relying only on a foreign regulator, or letting the sponsoring manager decide does not meet supervisory expectations.
- AObtain approval from senior management after gathering sufficient information about the respondent's business, reputation, and AML/CFT controlsCorrect
- BRely solely on the respondent bank's home regulator to certify that its controls are adequate
- COpen the account on a restricted basis and complete due diligence within the first year
- DDelegate the decision to the relationship manager who sponsored the respondent
Explanation
Guidance expects correspondent banks to gather enough information on the respondent's business, reputation, supervision and AML/CFT controls, and to obtain senior management approval before establishing the relationship. Relying only on a foreign regulator or deferring due diligence is inadequate, and approval should not rest with the sponsoring relationship manager.
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