AML / CTF / CPF / ROE & Sanctions 2023 - Autumn Update Quiz

Quiz for the webinar hosted by For Legal.

https://www.formediagroup.co.uk/forlegal/aml-ctf-cpf-roe-sanctions-autumn-update

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* 1. Respondent Details

First Name

Last Name

Company Name

Job Title

Email Address

Phone Number

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* 2. AML Multiple Choice Questions: July 2023

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* 3. A commercial client is seeking some additional funding and has asked you for legal advice. The client imports and resells laser equipment for use in academic research. You should ask the client about...

(a) Identification (ID) of the client company, terrorism and sanctions links

(b) ID of the company, terrorism, sanctions links, politically exposed person (PEP) links and counter-proliferation concerns

(d) ID of the client only

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* 4. Counter proliferation risks should be contemplated in which one of the following cases?

(a) All commercial clients

(b) All private clients

(d) All commercial clients where funding, insurance & shipping finance is concerned

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* 5. A fee-earner is acting for the foreign corporate owner of a substantial residence in Surrey. Before the fee-earner can register the transfer of the property, she must check that...

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* 6. (a) The owner has registered its ultimate individual beneficial owners on the Register of Overseas Entities (ROE) at Companies House

(b) The owner has registered its beneficial owners on the ROE at Companies House

(d) The owner has registered its ultimate individual beneficial owners on the ROE at the Treasury

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* 7. A fee-earner has discovered from his CDD enquiries that a banking client (introduced by an agent in Hong Kong) is a designated person on the UK sanctions list. He must now

(a) Cease all activity and decline to mention it for fear of tipping off the client

(b) Carry on, as banking activities are exempt from the Sanctions legislation

(d) Carry on, as the banking client should have been checked by the Hong Kong introducer

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* 8. A fee-earner in the commercial conveyancing team is acting for a UK-registered company buying land in London’s East End for redevelopment. In her CDD enquiries she has found that the company is a wholly-owned subsidiary of an American bank registered in Delaware. She should

(a) Investigate fully the identity of the ultimate individual beneficial owner behind the corporate structures

(b) Stop there, as the client is owned by an American bank and they will have CDD processes in place too

(d) Ensure that the holding company is on the Register of Overseas Entities

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* 9. In pursuing CDD enquiries on a corporate client, a fee-earner discovers that it is ultimately owned by the son of a member of the Gibraltarian government. This should...

(a) Cause no concern as Gibraltar is a ‘safe country’

(b) Cause the firm to undertake enhanced CDD as the client is a politically exposed person (PEP) in a high-risk third country

(d) Cause the firm to undertake simplified CDD as the client is a corporation

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* 10. If the firm discovers it is acting for a PEP it will need to

(a) Obtain senior approval to act, evidence of source of funds and undertake enhanced ongoing monitoring

(b) Obtain senior approval to act, evidence of source of wealth and undertake enhanced ongoing monitoring

(d) Obtain senior approval to act, evidence of source of wealth and funds (with verificatory evidence) and undertake enhanced ongoing monitoring

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* 11. In a UK-based conveyancing transaction, a client is asked to send the deposit sums (of £50,000) to the firm’s client account. The sum received was £500,000 and the client blames the mistake on his ‘fat fingers’ as he hit too many noughts on his keyboard. He asks that the £450,000 excess be sent on to a friend of his to whom he owes money. The firm should not do so, primarily because..

(a) this could be a breach of the banking legislation

(b) this could be a breach of the Accounts Rules

(d) this could be an attempted fraud

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* 12. In a ‘routine’ probate matter a fee-earner innocently, but negligently, failed to check a few points of oddity in the matter – a large suitcase of cash being found in the deceased’s property and some contemporaneous adverse media reports about the client’s shady past and his involvement in drugs gangs. She (the fee-earner) claimed she had been ‘rushed off her feet’ at the time and was surprised when the Police came to visit her at the firm’s premises. Of what criminal offence might the fee-earner be guilty?

(a) Entering into a transaction involving criminal property (s 328 PoCA)

(b) Acquiring criminal property for which no consideration has been given (s 329 PoCA)

(c) Failure to report reasonable grounds for suspicion of money laundering in the context of regulated business (s 330 PoCA)

(d) Tipping off a suspect (s 333A-D PoCA)

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* 13. A fee earner reports a matter to her MLRO on Monday 1st July. The report is made to the NCA on Tuesday 2nd July. It is electronically acknowledged by the NCA on Wednesday 3rd July. On what day could the firm legitimately undertake work on the matter in the absence of any further communication from the NCA?

(a) Friday 12 July

(b) Thursday 11 July

(d) Tuesday 9 July