Specimen Paper and Reflections – Anti Money Laundering

Module 3 (FICS Diploma in Anti Money Laundering) was the toughest paper of them all. I genuinely felt I could fail…

Anyhow, I shall not waste the learning opportunity that has come my way.

Perhaps one day, topics like these can be taught in schools so that the students will know what the world is truly like…

The examination format from a Specimen Paper (2009) gave learners 2 hours of response time and 15 minutes of reading time. Altogether, there were 3 mandatory essay questions.

I shall create a question modelled on one of them (Question 1).

Sharifah heads the Money Laundering and Compliance Department of Assured Financial Services (AFS) as the Money Laundering Reporting Officer (MLRO). (Her company is 250 strong). Sharifah’s team observes, among others, the account of Theo, a Taiwanese of Swiss and Taiwanese origins. Theo utilises AFS for his businesses, including investment firms that are based in Indonesia, Thailand and Laos.

Theo is SG’s fifth largest client, with a net worth of 300 million Euros. Momo, a former analyst for the Bank of Japan, is the Relationship Manager (RM). She has serviced the former’s account for 7 years. Resultantly, she became the top earner in the role for 5 out of the last 8 years. Momo invariably visits Theo in the above mentioned countries to discuss management of the latter’s assets on a frequent basis. It appears that the Know Your Customer (KYC) requirements regarding Theo were not duly completed and updated by Momo. This was confirmed when Momo was unwilling and unable to provide clear cut replies or details. Moreover, other personnel have voiced concerns about her general ‘less than compliant’ manner. Yet, the RM Vice President would hardly want to disturb the existing and profitable status quo by bothering or antagonising a star employee.

One day, Sharifah receives an anonymous internal tip-off indicating that Momo is actually assisting to launder drug sales income from Theo’s businesses. The whistleblower opines that drugs and firearms form the bulk of Theo’s wealth. After a low key investigation, Sharifah determines there is a need to make a Suspicious Transaction Report to the Commercial Affairs Department (CAD), Singapore Police Force. 

Assuming you are in the shoes of Sharifah:

a. How can you manage the internal reporting to the senior executives (do also consider the role and attitude of the RM Vice-President)

b. Should the CAD or other authority enact investigations on the matter, who should be designated as liaison? Further, who is to decide on the degree of co-operation and the type/quantity of replies to CAD’s queries; as well as other other related matters?

c. Which AFS units have to be brought in to participate? Which units do you have to seek information or guidance from?

(35 marks)

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