FROM THE - JOURNALS of Monte Friesner – Criminal & Intelligence Analyst and Consulaire for WANTED SA ~
Contributed & Written by Kenneth Rijock ~
DO NOT USE COUTTS DEFICIENCIES AS PEP GUIDELINES
If you did not have a chance to review the March FSA report on Coutts, you will find a number of good examples of what NOT to do when dealing with high-risk international clients. There's also a list in the report regarding Politically Exposed Persons (PEPS) and high-risk clients that I recommend you review, to see whether your programme measures up:
(1) Gather sufficient information about a prospective PEP and other high-risk customers, to establish their Sources of Wealth and income.
(2) Establish the Source of Funds received at the outset of the high-risk customer relationship.
(3) Gather sufficient information about prospective high-risk corporate customers, such as information regarding business activities, ownership and control structures and the intended purpose of the business relationship.
(4) Identify and/or assess adverse intelligence about prospective and existing high-risk customers properly, and take appropriate steps in relation to such intelligence.
(5) Keep the information on existing PEPs and other high-risk customers up-to-date.
(6) Scrutinise transactions made through PEP and other high-risk customer accounts appropriately.
These are excellent guidelines, and I recommend them; Our thanks to the FSA.
WANTED SA kindly thanks US Treasury, Kenneth Rijock, AFP, Reuters, BBC, Associated Press, DEA, FBI, ICE, Westlaw, Arutz Sheva, and all the Parties, Press, Journalists, Law Enforcement and Securities forces who have contributed to the many articles and their sincere opinions and statements.
WANTED SA states that the facts and opinions stated in this article are those of the author and not those of WANTED SA. We do not warrant the accuracy of any of the facts and opinions stated in this article nor do we endorse them or accept any form of responsibility for the articles.
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