You have recently been employed by Eire Bank (Dublin) as their Money Laundering Reporting Officer (MLRO). Eire Bank is authorized as a Financial Service Provider by the Central Bank of Ireland. Eire Bank has 1,500 employees.
Eire Bank has been selected by the Central Bank for a thematic inspection on AML (Financial Crime Prevention) and you are due an onsite inspection by the Central Bank in two weeks’ time. The Board of Eire Bank has asked you to confirm that all the necessary arrangements are in place.
Your Employment with Eire Dublin Bank (based on your understanding of the Professional Certificate in Combatting Money Laundering (AML) and Financial Crime Manual) is to:
a) Identify the key items that Eire Bank has in place in relation to the implementation of a robust Anti Money Laundering and Counter-Terrorist Financing Programme.
b) Identify the key risks Eire Bank considers and why the risks that should be considered for the organization.
c) Summarise the Suspicious Transaction Reporting process in Eire Bank.
d) the Board of Directors has also asked to identify if there is a need for an ethics policy to be put in place and give the reasons for your decision
As the MLRO for Eire Bank, you have now concluded the Central Bank of Irelands thematic inspection on AML (Financial Crime Prevention). There were no findings noted by the Central Bank of Ireland Team when completing the inspection. While the documentation was in the order you are concerned about the compliance culture within the firm.
a) As MLRO what recommendations would you make to improve the compliance culture at Eire Bank?
b) What impact does Integrated Assurance (3 lines of Defence) have on the compliance culture of a firm?
A financial service provider Ireland Bank plc through its risk analysis has identified some unusual activities. When investigated, Ireland Bank plc identified the following information: Company A received €1,250,000 from Company B in the form of a loan. By the next day Company A instructed the Bank to transfer the funds as follows:
• €750,000 into another bank account of Company A with Italy Bank plc.
• €500,000 issue of a banker’s draft in favor of Company C – based on the loan agreement.
• Following the above transactions, Company A instructed for the initial account used to close (8 months after the account was initially opened).
A month later in the accounts of Company C, a banker’s draft amounting to €750,000 was also deposited, from Company A’s account with Italy Bank. Further transactions were made from Company C’s account as follows:
• €656,000 issue of a banker’s draft in favor of Company D – based on a loan agreement
• €550,000 turned into a Fixed Deposit upon maturity of which the funds have been withdrawn in cash. Following the above transactions, Company C instructed for the account to close (after 8 months from opening).
A. What are the red flags which might indicate money Laundering / terrorist financing activities have occurred in this case? In your answer, please indicate the transaction and the relevant red flag this relates to
B. What are the risks and potential threats that the Financial Services Provider may be faced with in this situation?
C. What due diligence work should the Financial Services Provider have carried out and when?
D. Discuss the impact the Covid-19 Pandemic has had on the different types of Financial Crime has had on Financial services globally.
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