Mastering Anti-Money Laundering and Counter-Terrorist Financing (The Mastering Series) by Parkman Tim

Author:Parkman, Tim [Parkman, Tim]
Language: eng
Format: epub
Publisher: Pearson Education Limited
Published: 2019-11-28T16:00:00+00:00

Case 1 – Ace Construction Limited

Ace Construction Limited is registered in your country and doing business there, specialising in so-called ‘intelligent’ buildings. Through a recently won large new contract, it is also doing business in Nigeria. The company was founded six months ago by directors and shareholders (who are also the beneficial owners) David Harman and Peter Markin on the back of two initial, specialist, small office construction contracts undertaken for a Nigerian company which wants to use the technology in their new head office building. Herman Taylor, a local lawyer, holds a power of attorney and is also an authorised signatory.

What risk classification would be appropriate for this relationship and what CDD information and verification should be obtained?

The answer in this case is that this is an EDD classified relationship. From the facts, we can determine immediately that it cannot be an SDD account because it does not fulfil any of the criteria for SDD status that we outlined earlier (it isn’t publicly quoted, it isn’t subject to statutory licensing and it isn’t government-owned or controlled). We also know that it doesn’t have to be EDD, because none of the features triggering mandatory EDD status are present (there are no PEP connections, the company is not involved in the gambling, armaments or diamond/precious metals trade, it is not an offshore trust, it doesn’t issue bearer shares and it doesn’t have a complex ownership structure, as defined). Since it cannot be SDD and need not be EDD, therefore, it could be either NDD or EDD and to determine this we refer to the corporate banking risk calculator. The relevant criteria for using this calculator are country risk (Nigeria = high: remember that the country risk will be the higher of the place of incorporation and place of business, if different), business sector risk (construction = medium) and business age (less than one year = high), according to which the overall classification using the calculator comes out at EDD, as shown in Figure 4.7.

In terms of the information and verification requirements, if we look at the CDD documentation tool we can see that the CDD requirements for this business in the EDD section would therefore be as follows.

Download

Copyright Disclaimer:
This site does not store any files on its server. We only index and link to content provided by other sites. Please contact the content providers to delete copyright contents if any and email us, we'll remove relevant links or contents immediately.