Assignment Task: Roberta is a compliance analyst at Compco, a large regulated financial services firm, whose head is based in Europe. CompCo had several subsidiaries globally.
During a recent customer review, Roberta has become concerned about several notes she has found, in customers' files, about potential risk indicators flagged by relationship managers (RMs) that have never been followed up on. These include
1. Several customers with links to Russia whose sources of wealth and sources of funds were noted as never having been established
2. Many RMs recorded concerns about different account activities but at client meetings, where more information about their activities was sort, clients were recorded as being aggressive, threatening to take their business elsewhere.
3. In cases where clients had businesses that involved different entities, the RMs seem to have investigated beneficial ownership to some extent, but there were several notes in the files stating investigations came to a halt owing to a lack of information
4. As a general point or due to the review of the files. Roberta also makes the observation that it appears that there may be a very small number of internal money laundering suspicion reports, commensurate with the size of the firm and the number of accounts operated.
What are the implications of the facts contained therein them?
Whether Unusual activities reports (UAR or internal suspicious reports) or suspicious activities reports (SAR)/suspicious transactions reports (STR) should have been submitted and why and to where. What are the implications or possible implications to the firm?
In great detail and by using examples provide guidance on the above.