Javier and his team have received several requests from RMs who have been approached by clients resident in European countries: Anti Money Laundering Assignment, ICTA, Ireland
| University | International Compliance Training Academy (ICTA) |
| Subject | Anti Money Laundering |
- Javier and his team have received several requests from RMs who have been approached by clients resident in European countries, where SYK has no branches. The RMS often recommends that the new accounts utilize correspondent banks in order to facilitate business opportunities. They are aware that Correspondent Banks present some risk, but need advice on the extent of that risk.
- Some RMs is unclear under what circumstances a constructive trust situation may occur. Various concerns have been raised and Javier and his team’s advice sought, over circumstances where a Suspicious Activity Report/Suspicious Transaction Report has been made. The concerned firms are keen to avoid any breach of constructive trusteeship and need advice on their duties as a trustee.
- There has been confusion amongst some RMs over the firm’s client exiting process. They wish to know what the key principles are, and on which the exit strategy is based. They are concerned that in the event of a poorly executed exit or an exit that is carried out without a proper foundation, they would be placing the firm at risk.
- Since 2020 there have been an increasing number of accounts that involve trade
finance. On many occasions, the RMs report that these accounts are connected with the
shipment of high-value low volume goods, including consumer electronics. They want further advice on how to proceed when clients are involved in this type of trade and what risk indicators they need to be aware of.
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