Which control would be most effective as part of a risk-based approach (RBA) to managing AML/CFT risk for a bank established in the EU that also has a branch in a high-risk third country outside of the EU?
A.
Fully rely on central beneficial owner registry records in the high-risk third country to determine the ultimate beneficial owners of all customers
B.
Apply tailored due diligence measures, based on the level of risk posed by each customer following risk assessment
C.
Monitor every cross-border transaction in real time, flagging all for enhanced scrutiny due to the country risk level
D.
Automatically apply enhanced customer due diligence measures to all customers in the high-risk third-country branch regardless of risk level
As part of a risk-based approach, the bank should apply tailored due diligence measures based on the assessed risk level of each customer. This ensures resources are focused where they are most needed, rather than applying uniform enhanced measures to all customers, which can be inefficient and unnecessary.
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