What is the role of policies and procedures as aspects of an institution's sanctions
compliance program? - answers-they identify, interdict, escalate, report, and maintain
records concerning potentially prohibited activities.
Which of the following is a way in which a cutomer's delivery channel might increase an
fis inherent risk? - answers-the affiliate providing the due dil on the customer is in a
jurisdiction with low compliance standards.
What a common error/assumption made about sdd? - answers-a customer that has no
obvious presence or direct link to a sanctioned country is low sanctions risk.
Customers whose business involve trade-related activities warrant close attention in
regard to the nature of business and product and services b/c - answers-cargo can be
transferred from one ship or other form of transport via another country b4 arriving at its
final destination
What constitutes an operational challenge that can be encountered when attempting to
identify beneficial owners? - answers-unreliable information from the the new customer,
data silos, high volume business, calculation of aggregate ownership.
Which item relates to a customers jx/geo as part of the customer's sanctions risk
profile? - answers-place of birth, tax residency and travel for work (does customer travel
regularly to a country that is subject to comprehensive sanctions and if so, how is the
travel funded.
How does the scope of kyc info used for sanctions compliance differ from that used for
aml requirements? - answers-the scope of kyc information for sanctions compliance can
be more limited than for aml purposes. But it should at least include ( id of
customer/counterparties/bo, nature of and purpose of customer's account/tx, source of
funds and where they intend to send them).
Aml kyc need to understand exposure to all high risk countries - sanctions just need to
know exposure to sanctioned countries.
What are the key information to collect for sanctions sdd? - answers-the customer,
nature of business, geo/jx connections
Which items are primary sources of information that can be used in an investigation?
Corporate registers or key trade activity lists - answers-key trade activity list. These lists
are the dpl list, common military list of the eu, us nuclear regulatory commission controls
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