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FRM Part II · FRM Exam Part II · Sound Management of Risks Related to Money Laundering and Financing of Terrorism

A private bank is onboarding a client who is a senior foreign government official's close associate and will hold a large account funded by offshore transfers. Which action is most consistent with sound ML/FT risk management for this relationship?

The bank should apply enhanced due diligence: establish source of wealth and source of funds, obtain senior management approval, and monitor the account more closely. Politically exposed persons and close associates are higher risk, so standard CDD or sole reliance on an introducer is inadequate.

  1. AOpen the account under standard CDD and review it only if an alert is generated
  2. BDecline to document the source of wealth to protect client confidentiality
  3. CApply enhanced due diligence, including establishing source of wealth and funds, with senior management approval and enhanced ongoing monitoringCorrect
  4. DRely entirely on the introducer's assurance without independent verification

Explanation

Politically exposed persons and their close associates are higher-risk and call for enhanced due diligence, source of wealth/funds checks, senior management approval and closer monitoring. Standard CDD with alert-only review is insufficient, and relying wholly on an introducer leaves the bank responsible for the outcome.

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