Trust and company service providers (TCSPs) should address money laundering risk by: (Select Three.)
A.
Establishing dual controls and quality assurance practices when processing transactions for the client
B.
Considering what additional safeguards may be required when client instructions are given through another TCSP located in another jurisdiction
C.
Requiring the client to complete and submit an AML risk self-assessment to the jurisdiction’s Financial Intelligence Unit (FIU)
D.
Gathering and recording information from clients to understand the purpose of the legal entity, as well as the identity of managers and ultimate beneficial owners
E.
Establishing procedures to document the basis on which the TCSP will act as a registered officer for the client and retaining records of that involvement
F.
Conducting an onsite evaluation of the client to assess internal controls
Trust and company service providers (TCSPs) are classified as higher-risk entities under FATF guidance due to their role in forming and managing legal structures. As a result, TCSPs must implement robust AML controls to mitigate misuse for money laundering.
A key requirement is gathering and recording detailed client information, including the purpose of the legal entity and the identity of managers and ultimate beneficial owners (UBOs). This supports effective customer due diligence and transparency.
TCSPs must also apply additional safeguards when relying on instructions from another TCSP, particularly one located in a different jurisdiction. Reliance on intermediaries increases risk and requires enhanced scrutiny.
Additionally, TCSPs should document the basis on which they act as a registered officer and retain records of their involvement. This ensures accountability and traceability in line with record-keeping obligations.
Requiring clients to submit AML self-assessments to an FIU and conducting onsite evaluations are not standard or required practices under AML frameworks.
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