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CS Professional · IFSCA - Regulations, Listing and Compliances · Book-keeping, Accounting, Taxation and Financial Crime Compliance Services and TAS

Arjun Fintech, a service provider in GIFT IFSC, performs transaction monitoring for three different banking units under separate contracts. It stores all clients' alerts in one shared folder accessible to every analyst, and a bank unit asks for its records during a regulatory inspection. Which assessment is most accurate?

The arrangement reflects weak control. The provider should keep each client's records confidential, segregated and quickly retrievable for inspection, and the regulated bank unit stays accountable for its own compliance even after outsourcing, so a shared open folder is inadequate.

  1. AAcceptable, because the provider owns the data it processes
  2. BWeak control: the provider must maintain confidentiality, segregation and ready retrievability of each client's records, while the regulated entity remains responsible for its complianceCorrect
  3. CAcceptable, provided the folder is password protected once a year
  4. DAcceptable, since the bank unit's responsibility ends on outsourcing

Explanation

Outsourcing does not shift the regulated entity's accountability, and records must be confidential, segregated and retrievable for inspection. A shared open folder fails these needs; an annual password does not cure it, and ownership of data does not rest with the provider.

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