Question

Submitting your assignment  

1. Please collate your assignment as a single document in a Microsoft Word format.

2. Save the assignment as your candidate ID number, e.g. CON-000123456.

3. All marking is anonymous, which means your name should not appear on your work.

4. You must state which region/jurisdiction you are from in the header of each page.

5. You must ensure that all your work is properly referenced.

6. Penalties will be applied to those candidates who submit their assignment after the due date.

Word count

7. The total word count for this assignment should be between 2,000 and 2,500 words. This includes all in text references and appendices but excludes any footnotes, reference page or contents page. N.B. Appendices should only be used in exceptional circumstances and should consist of only brief extracts or tables.

8. The number of words per question should reflect the number of marks allocated.

9. Penalties will be applied for excessive overall word count.

All parts of the question can be answered in relation to a jurisdiction with which you are familiar.

Where a specific jurisdiction has been selected, this should be clearly stated in your answer.

Answer all parts of the question.

Question

Olivia is a director and money laundering reporting officer (MLRO) of NRO Bank, a small local bank based in a jurisdiction of your choice. She is responsible for a number of areas of the Bank's operations, including the Human Resources division and New Business Acquisition, as well as bearing the AML responsibilities.

Olivia has a strong personality and is trusted by the Bank's board, who rely on her to get things done. She is rarely challenged by other members of the board or other staff members.

The Bank has recently been the subject of a regulatory visit and the report that followed has been highly critical of both the board and the MLRO. Key criticisms included the following failings.

• • A failure on the part of the MLRO to process internal suspicious activity reports (SARs)/suspicious transaction reports (STRs) and externalise them to the Financial Intelligence Unit (FIU) (26 in total, with some as old as 18 months).

• • The MLRO deliberately misled the board into believing that money laundering was not a significant issue within the Bank. She deliberately failed to notify the board that internal SARs had been made.

• • The board of the Bank failed to meet regularly and did not monitor the internal AML reporting system and processes.

• • The MLRO was an extremely powerful individual and deemed unapproachable by members of staff.

• • The Bank prioritised business development over compliance.

• • From a corporate governance perspective, it was inappropriate for Olivia to control so many other areas of the Bank's operations while also carrying out the MLRO role.

Q)What remedial action do you believe the Bank should take in order to remedy the issues highlighted?

The country/jurisdiction to be selected is DUBAI

Answer 1

Remedial action bank should take are as follows:

Configured to the individual needs of your firm, smart AML can significantly reduce noise and false positives but it obviously won't eliminate money laundering threats completely, or indeed the need to deal with them.

Smart technology can also impact the way you make decisions about the money laundering threats you face, speeding the way you remediate and report, generating meaningful insights, and passing efficiency benefits on to clients.

Smart AML solutions incorporate contextual data and automation to speed the decision making process while connecting with other platforms in order to further streamline. when a client breaks a rule by doing business in Dubai, for example, their KYC (know your customer)profile, informed by reactive, smart technology, may have already indicated their plans to expand meaning your firm can react quickly to remediate and report the alert.

Escalation and Communication:

Ensure your AML tools let you escalate your suspicious activity reports quickly and, just as importantly, communicate clearly with your compliance team.

Sourcing data:

data is crucial to smart AML firms should carefully consider the provider they use to source it. determine the quality of data with four factors Scope, Depth, Reactiveness, Consolidation

Embracing Change:

Smart AML is only effective as a convergence of technology and data, and the will of financial institutions to transform their compliance function.embracing the smart approach is a way to empower compliance, and compliance teams, in an often confusing threat landscape and means treating compliance as a living, breathing process which can grow and change with the needs of institutions and their cutomers.