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

Which describes the expected role of group-level AML/CFT compliance with respect to information sharing across a banking group's branches and subsidiaries?

Group-level compliance and AML functions should be able to obtain relevant customer, account and transaction information from branches and subsidiaries to manage ML/FT risk on a consolidated basis, with proper safeguards on confidentiality and use of that information.

  1. AGroup-level functions should be able to obtain customer, account and transaction information from branches and subsidiaries when needed for ML/FT risk management, with safeguards on confidentiality and useCorrect
  2. BEach subsidiary should keep all customer data strictly local and never provide it to group functions
  3. CInformation should be shared only after a law enforcement request has been issued
  4. DOnly the CEO of the group should receive suspicious transaction information

Explanation

Group-wide risk management requires group compliance, audit and AML functions to access relevant customer, account and transaction information, including unusual activity analysis, subject to adequate safeguards on confidentiality and use. Strict local silos undermine a consolidated view of risk.

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