Passed Exam Today CAMS

 Submitting the concern anonymously to the bank’s internal Compliance Hotline is the most appropriate action that a bank CEO’s assistant should take when the bank CEO expenses large sums of money to a charitable organization run by the bank CEO’s direct family member. This is because this action would allow the assistant to report a potential case of fraud, conflict of interest, or misuse of funds without fear of retaliation or reprisal from the bank CEO. The Compliance Hotline is a confidential and secure channel for employees to raise any concerns or suspicions about unethical or illegal activities within the bank. The Compliance Hotline would then forward the concern to the relevant authorities or departments for further investigation and action.

References: = The main references for this question are the following sources:

The document titled “Anti-Fraud Policy” published by the World Bank Group. You can access it by clicking here. This document states that "The World Bank Group has established a Compliance Hotline to receive reports of suspected fraud or corruption in World Bank Group-financed projects or activities, or in the World Bank Group’s corporate procurement or administrative activities. The Compliance Hotline is available to all staff and external parties, such as contractors, consultants, beneficiaries of World Bank Group-financed projects, and the general public.

The potential red flag that alludes to money laundering is option B, where the trio engage in minimal gambling and combine the funds to request a casino cheque for the chips presented. This behavior is indicative of structuring, which involves breaking down large transactions into smaller ones to avoid detection by the casino and regulatory authorities. The fact that the trio only used a small amount of chips to play games, and then combined their funds to request a casino cheque, raises suspicions that they may be attempting to disguise the origin of their funds.

Compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies. This is stated in the Certified Anti-Money Laundering Specialist (the 6th edition) manual on page 595, which states: “Sanctions screening requirements include that a financial institution should compare customer and transaction records against periodically updated sanctions lists provided by governmental bodies.”

Lawyers who lack experience in providing specific services requested by clients or receive unusually high fees can raise red flags for money laundering. Inadequate documentation of case notes may also be suspicious, but the absence of experience and excessive fees are more significant indicators. These behaviors warrant further scrutiny to assess potential money laundering risks12.

References:

1. ComplyAdvantage: AML Red Flags – What are the Top 10 Indicators?

2. HyperVerge: AML Red Flags: A Guide to Identification and Response