Banking · Anti-Money Laundering (AML)
Consider the following statements regarding the operational implementation of Risk Categorization and Transaction Monitoring in the context of AML guidelines. Statement 1: Banks are mandated to categorize their customers into Low, Medium, and High-risk categories based on various parameters such as identity, social/financial status, and location. Statement 2: High-risk customers include PEPs, non-resident customers, trusts, charities, NGOs, and firms with sleeping partners. Statement 3: The risk categorization of every customer must be reviewed periodically, with the RBI suggesting a review at least once every six months for all categories. Statement 4: Transaction monitoring requires the use of automated systems in all banks regardless of their size. Statement 5: For high-risk accounts, the bank must perform Enhanced Due Diligence (EDD), involving deeper scrutiny into the source of wealth. Statement 6: The bank's internal threshold for generating alerts must be kept confidential from customers and frontline staff to prevent tipping-off. Statement 7: If a transaction is flagged as suspicious, the bank has a maximum of 30 days to investigate, and during this investigation, the account must be suspended. Which evaluation of these statements is correct according to the regulatory framework?
- 1Only Statements 1 and 2 are correct because risk categorization is a subjective process and other operational aspects are left entirely to the discretion of the bank's Board.
- 2Statements 1, 2, 4, 5, and 6 are correct, but Statement 3 is incorrect as the review is usually annual or as per internal risk policy, and Statement 7 is incorrect because the reporting timeline for STR is 7 days once suspicion is confirmed.✓
- 3All seven statements are correct as they form the backbone of a robust Anti-Money Laundering and Counter-Terrorist Financing framework.
- 4Statements 1, 2, 5, and 6 are correct, while Statement 3 is incorrect because the review frequency is not six months, Statement 4 is correct, and Statement 7 is incorrect because investigation doesn't require account suspension.
Correct answer
Statements 1, 2, 4, 5, and 6 are correct, but Statement 3 is incorrect as the review is usually annual or as per internal risk policy, and Statement 7 is incorrect because the reporting timeline for STR is 7 days once suspicion is confirmed.
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